Cite as: 524 U. S. 184 (1998)
Opinion of the Court
fied by a disregard of a known legal obligation,26 willful was also interpreted variously to refer to "purposeful, intentional conduct," 27 "indifferen[ce] to the requirements of the law," 28 or merely a "conscious, intentional, deliberate, voluntary decision." 29 Moreover, in each of the cases in which disregard of a known legal obligation was held to be sufficient to establish willfulness, it was perfectly clear from the record that the licensee had knowledge of the law; 30 thus, while these
26 See, e. g., Perri v. Department of the Treasury, 637 F. 2d 1332, 1336 (CA9 1981); Stein's Inc. v. Blumenthal, 649 F. 2d 463, 467-468 (CA7 1980).
27 Rich v. United States, 383 F. Supp. 797, 800 (SD Ohio 1974).
28 Lewin v. Blumenthal, 590 F. 2d 268, 269 (CA8 1979); Fin & Feather Sport Shop v. United States Treasury Department, 481 F. Supp. 800, 807 (Neb. 1979).
29 Prino v. Simon, 606 F. 2d 449, 451 (CA4 1979) (internal quotation marks omitted); see also Stein's, 649 F. 2d, at 467 ("[I]f a person 1) intentionally does an act which is prohibited, irrespective of evil motive or reliance on erroneous advice, or 2) acts with careless disregard of statutory requirements, the violation is willful" (internal quotation marks omitted)).
30 Perri, 637 F. 2d, at 1336 ("The district court found Perri knew a straw-man transaction would violate the Act"); Stein's, 649 F. 2d, at 468 ("The record shows that the plaintiff's agents were instructed on the requirements of the law and acknowledged an understanding of the Secretary's regulations. Nevertheless, and despite repeated warnings from the Secretary, violations continued to occur" (footnote omitted)); Powers v. Bureau of Alcohol, Tobacco and Firearms, 505 F. Supp. 695, 698 (ND Fla. 1980) ("Bureau representatives inspected Powers August 31, 1976. They pointed out his many violations, gave him a copy of the regulations, thoroughly explained his obligations, and gave him a pamphlet explaining his obligations. As of that date Powers knew his obligations"); Shyda v. Director, Bureau of Alcohol, Tobacco and Firearms, 448 F. Supp. 409, 415 (MD Pa. 1977) ("[A]t the formal administrative hearing petitioner admitted on the stand under oath that he was aware of the specific legal obligation at issue"); Mayesh v. Schultz, 58 F. R. D. 537, 540 (SD Ill. 1973) ("The uncontroverted evidence shows clearly that plaintiff was aware of the above holding period requirements. Mr. Mayesh had been previously advised on the requirements under Illinois law, and he clearly acknowledged that he was aware of them"); McLemore v. United States Treasury Department, 317 F. Supp. 1077, 1078 (ND Fla. 1970) (finding that both
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