Paul Moise operated tax-preparation businesses and was convicted of filing returns that claimed deductions and income figures he knew were false. During rebuttal, the prosecutor made an improper “South Park”/“shyster” remark after defense counsel attacked the government’s tax calculations. The Eleventh Circuit held that the remark was improper but invited by the defense argument, promptly cured by instruction, and harmless in an eight-day trial; it affirmed the convictions.