Lost in the avalanche of commentary about federal election law is the remarkable fact that a Manhattan jury actually may have convicted former President Donald Trump of overpaying taxes.

The prosecution’s theory of the case was that a misdemeanor of falsifying business records could be upgraded to a felony if the purported falsification was in furtherance of another felony. From the initial indictment throughout the trial, the prosecution was cagey on precisely what additional felony was being alleged. References were made to New York election law and to federal election law. But it wasn’t until its closing argument that the prosecution explicitly unveiled its new theory: Tax fraud through overpayment.