the theory that it tended to prove the criminal ‘system’ of [the defendant].” Id. at 914. The court required the extraneous offense to be “so nearly identical in method to the charged offense as to earmark them as the handiwork of the accused.” Id. at 914-15 (internal quotations omitted). The similarity required to prove a “defendant’s system” naturally is high because the extraneous offense evidence is being used to show the defendant’s distinctive and idiosyncratic manner of committing the criminal acts. Id. We hold that it does not follow that an extraneous offense admitted to rebut the defensive theory of frame-up requires this same degree of exacting similarity between the extraneous and charged offenses. Cf. Plante v. State, 692 S.W.2d 487, 492-93 (Tex.Crim.App.1985) (En banc) (<HOLDING>). Moreover, the facts in Wheeler do not support
holding evidence of virtually identical offense was relevant to show intent among other things in trial of charged offense holding extraneous conduct subsequent to the charged offense admissible holding proof of racially discriminatory intent or purpose required to show equal protection violation holding that high degree of similarity between extraneous and charged offense used in cases proving modus operandi not required when purpose of proof is to show intent holding extraneous acts relevant to show intent in charged offense