In People v. Cohen, 52 N.Y.2d 584 (1986) after holding that reference to the name and number of the tax statute in the count to which the defendant pled guilty sufficed to give him notice that he was charged with a "willful" failure to file, the Court of Appeals offered an additional observation. Specifically, the Court noted that it was "unrealistic ... to splinter the analysis of the many charges in this case, which involved a multicount indictment clearly indicating that the People intended to prove willfulness, and allow a challenge to the one count to which a plea was taken on the theory that that particular count provided insufficient notice." (52 N.Y.2d at 587.)