The Second Circuit also reiterated in United States v. Nkansah that to obtain a conviction for bank fraud, the government must prove the defendant (1) engaged in a scheme designed to obtain money from a bank and (2) intended for the bank to be a victim by exposing the bank to actual or potential loss. The case involved a scheme to fraudulently obtain illicit tax refunds from the Internal Revenue Service by filing bogus tax returns. To complete the fraud, the defendants opened several bank accounts under fake names into which they deposited the tax-refund checks from the Department of the Treasury. The appeals court held there was insufficient evidence that the defendants intended to harm the banks, even though there was plenty of evidence they intended to harm the Treasury.