Tax Preparer’s Conviction Properly Supported by Personal Returns

A Maryland tax preparer was properly found guilty on 23 counts of aiding and assisting in falsified tax returns, the Fourth Circuit held Friday, rejecting his argument that the lower court improperly allowed evidence of his own fraudulent tax returns.

Ronald Watson appealed his conviction and 27-month prison sentence, arguing the lower court violated Rule 404 (b) of the Federal Rules of Evidence by admitting his personal tax returns for 2017 and 2018 even though they weren’t part of the charges against him.

Rule 404(b) evidence of other crimes and wrongs are prohibited if they are used to prove a person’s character, because it could “overpersuade” a jury into believing that a criminal defendant is generally bad, the US Court of Appeals for the Fourth Circuit said in an unpublished, unsigned opinion.

However, the rule allows such evidence if it is used to prove things such as motive, opportunity, and lack of mistake, the court said. The evidence still must be relevant to an issue that’s not the defendant’s character, necessary to prove an element of the offense, reliable, and admissible in the sense that its value isn’t outweighed by its prejudicial nature.

The court said Watson’s personal tax returns were justified because he similarly falsified and exaggerated them as he did with his clients.

The tax returns also met all four requirements for admission, and therefore the lower court didn’t abuse its discretion, the appeals court said.

Judges Julius N. Richardson, Allison Rushing, and DeAndrea Benjamin issued the decision.

Watson is represented by Bell, Davis & Pitt PA.

The case is United States v. Watson, 4th Cir., No. 23-04756, unpublished 6/20/25.