7203 - Bank Records and Net Worth Increases 5 Page 2

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Articles by Alvin Brown
Tax Preparation
Offer In Compromise
State Offers in Compromise
Levy
IRS Tax Liens
IRS Tax Liens - continued
IRS Tax Liens - continued 2
Levy - continued
IRS Audits
Audit Techniques Guide
Congressional Contacts
Criminal Investigation
D.O.J Criminal Tax Manual
Tax Litigation
Penalty
Installment Agreements
Statute of Limitations
Frivolous Tax Argument
Interest Abatement
IRS Misconduct
IRS Abuses
Tax Fraud
Fraud Statutes
Bankruptcy
Tax Reform Legislation
Tax Shelters
Tax Court
Trust Fund Penalty
Legislation
Innocent Spouse Relief
Important Links


Fraud Statutes 

Additional Information:

 

7203 - Accountant-Client Privilege
7203 - Accrual Basis
7203 - Admissibility 1 p1
7203 - Admissibility 1 p2
7203 - Admissibility 1 p3
7203 - Admissibility 1 p4
7203 - Admissibility 1 p5
7203 - Admissibility 1 p6
7203 - Admissibility 2 p1
7203 - Admissibility 2 p2
7203 - Admissibility 2 p3
7203 - Admissibility 2 p4
7203 - Admissibility 2 p5
7203 - Admissibility 3 p1
7203 - Admissibility 3 p2
7203 - Admissibility 3 p3
7203 - Admissibility 3 p4
7203 - Admissibility 3 p5
7203 - Admissibility 4 p1
7203 - Admissibility 4 p2
7203 - Admissions p1
7203 - Admissions p2
7203 - Advice of Counsel p1
7203 - Advice of Counsel p2
7203 - Amendment
7203 - Appeal Right to
7203 - Appeal Timeliness
7203 - Appeal Waiver
7203 - Appeal without merit
7203 - Arrest
7203 - Fraudulent Return
7203 - Defeat & Evade Income Taxes p1
7203 - Defeat & Evade Income Taxes p2
7203 - Defeat & Evade Income Taxes p3
7203 - Defeat &  Evade Income Taxes p4
7203 - Attorney Disqualified
7203 - Attorney's Testimony p1
7203 - Attorney's Testimony p2
7203 - Attorney's Testimony p3
7203 - Attorney's Testimony p4
7203 - Bail
7203 - Bank Records &  Net Worth Increases 1 p1
7203 - Bank Records &  Net Worth Increases 1 p2
7203 - Bank Records &  Net Worth Increases 1 p3
7203 - Bank Records &  Net Worth Increases 1 p4
7203 - Bank Records &  Net Worth Increases 1 p5
7203 - Bank Records &  Net Worth Increases 1 p6
7203 - Bank Records &  Net Worth Increases 2 p1
7203 - Bank Records &  Net Worth Increases 2 p2
7203 - Bank Records &  Net Worth Increases 2 p3
7203 - Bank Records &  Net Worth Increases 2 p4
7203 - Bank Records &  Net Worth Increases 2 p5
7203 - Bank Records &  Net Worth Increases 3 p1
7203 - Bank Records &  Net Worth Increases 3 p2
7203 - Bank Records &  Net Worth Increases 3 p3
7203 - Bank Records &  Net Worth Increases 3 p4
7203 - Bank Records &  Net Worth Increases 3 p5
7203 - Bank Records &  Net Worth Increases 4 p1
7203 - Bank Records &  Net Worth Increases 4 p2
7203 - Bank Records &  Net Worth Increases 4 p3
7203 - Bank Records &  Net Worth Increases 4 p4
7203 - Bank Records &  Net Worth Increases 4 p5
7203 - Bank Records &  Net Worth Increases 5 p1
7203 - Bank Records & Net Worth Increases 5 p2
7203 - Bank Records & Net Worth Increases 5 p3
7203 - Bank Records & Net Worth Increases 5 p4
7203 - Bank Records & Net Worth Increases 5 p5
7203 - Base Sentence p1
7203 - Base Sentence p2
7203 - Base Sentence p3
7203 - Base Sentence p4
I7203 - Bill of Particluar Conspiracy
7203 - Bill of Particulars
7203 - Books and Records
7203 - Burden of going forward with evidence
7203 - Burden of Proof
7203 - Carryback Offset
7203 - Changing Plea
7203 - Character witness p1
7203 - Character witness p2
7203 - Circumstanial Evidence p1
7203 - Circumstanial Evidence p2
7203 - Circumstanial Evidence p3
7203 - Circumstanial Evidence p4
7203 - Collateral Estoppel
7203 - Collection
7203 - Commitment by U.S. Commissioner
7203 - Communication to Jury
7203 - Compromise
7203 - Consolidation
7203 - Conspiracy p1
7203 - Conspiracy p2
7203 - Conspiracy 1 p1
7203 - Conspiracy 1 p2
7203 - Conspiracy 1 p3
7203 - Conspiracy 1 p4
7203 - Conspiracy 1 p5
7203 - Conspiracy 1 p6
7203 - Conspiracy 1 p7
7203 - Conspiracy 1 p8
7203 - Conspiracy 2 p1
7203 - Conspiracy 2 p2
7203 - Conspiracy 2 p3
7203 - Constitutional Grounds 1 p1
7203 - Constitutional Grounds 1 p2
7203 - Constitutional Grounds 1 p3
7203 - Constitutional Grounds 1 p4
7203 - Constitutional Grounds 1 p5
7203 - Constitutional Grounds 2 p1
7203 - Constitutional Grounds 2 p2
7203 - Constitutional Grounds 2 p3
7203 - Constitutional Grounds 2 p4
7203 - Constitutional Grounds 2 p5
7203 - Constitutional Grounds 3 p1
7203 - Constitutional Grounds 3 p2
7203 - Constitutional Grounds 3 p3
7203 - Constitutional Grounds 3 p4
7203 - Constitutional Grounds 3 p5
7203 - Constitutional Grounds 4 p1
7203 - Constitutional Grounds 4 p2
7203 - Constitutional Grounds 4 p3
7203 - Constitutional Grounds 4 p4
7203 - Constitutional Grounds 5 p1
7203 - Constitutional Grounds 5 p2
7203 - Constitutional Grounds 5 p3
7203 - Constitutional Grounds 5 p4
7203 - Constitutional Grounds 5 p5
7203 - Constitutional Grounds 6
7203 - Contempt Finding Ag. Defendant's Counsel
7203 - Continuance p1
7203 - Continuance p2
7203 - Continuance p3
7203 - Conviction Required
7203 - Copies of Records p1
7203 - Copies of Records p2
7203 - Corporation Officer
7203 - Costs
7203 - Credit for Time Served
7203 - Criminal Contempt
7203 - Cross-Examination PART 1 p1
7203 - Cross-Examination PART 1 p2
7203 - Cross-Examination PART 1 p3
7203 - Cross-Examination PART 1 p4
7203 - Cross-Examination PART 1 p5
7203 - Cross-Examination PART 2
7203 - DefendantHaving Facts Available p1
7203 - DefendantHaving Facts Available p2
7203 - DefendantHaving Facts Available p3
7203 - Degree of Proof p1
7203 - Degree of Proof p2
7203 - Depositions
7203 - Different Statute Cited
7203 - Discovery, Scope Of
7203 - Documentary Evidence in Jury Room
7203 - Double Jeopardy 1 p1
7203 - Double Jeopardy 1 p2
7203 - Double Jeopardy 1 p3
7203 - Double Jeopardy 1 p4
7203 - Double Jeopardy 1 p5
7203 - Double Jeopardy 2 p1
7203 - Double Jeopardy 2 p2
7203 - Double Jeopardy 2 p3
7203 - Double Jeopardy 2 p4
7203 - Enhanced Sentence Sophisticated Means p1
7203 - Enhanced Sentence Sophisticated Means p2
7203 - Enhanced Sentence p1
7203 - Enhanced Sentence p2
7203 - Entrapment
7203 - Erroneous calculation of tax
7203 - Exclusion of Oral Testimony
7203 - Exercise Privilege-Exclusion from Courtroom
7203 - Expert Witness p1
7203 - Expert Witness p2
7203 - Expert Witness p3
7203 - Expert Witness p4
7203 - Extenuating Circumstances
7203 - Fact Finding p1
7203 - Fact Finding p2
7203 - Fact Finding p3
7203 - Fact Finding p4
7203 - Fact Finding p5
7203 - Failure of IRS to File Return
7203 - Failure to Assess Tax
7203 - Failure to Prosecute p1
7203 - Failure to Prosecute p2
7203 - Failure to Prosecute p3
7203 - Failure to Prosecute p4
7203 - Failure to Prosecute p5
7203 - Failure to Report Income 1 p1
7203 - Failure to Report Income 1 p2
7203 - Failure to Report Income 1 p3
7203 - Failure to Report Income 1 p4
7203 - Failure to Report Income 1 p5
7203 - Failure to Report Income 1 p6
7203 - Failure to Report Income 2 p1
7203 - Failure to Report Income 2 p2
7203 - Failure to Supply Information
7203 - False Return
7203 - Fictitious names
7203 - Fraud Case Procedures p1
7203 - Fraud Case Procedures p2
7203 - Fraud Case Procedures p3
7203 - Fraud Case Procedures p4
7203 - General Exception
7203 - Good Faith p1
7203 - Good Faith p2
7203 - Good Faith p3
7203 - Good Faith p4
7203 - Government Agent Prosecuting Claim
7203 - Grand Jury 1 p1
7203 - Grand Jury 1 p2
7203 - Grand Jury 1 p3
7203 - Grand Jury 1 p4
7203 - Grand Jury 1 p5
7203 - Grand Jury 2 p1
7203 - Grand Jury 2 p2
7203 - Hearsay Evidence p1
7203 - Hearsay Evidence p2
7203 - Hearsay Evidence p3
7203 - Hearsay Evidence p4
7203 - Hearsay Evidence p5
7203 - Hostility of the Court p1
7203 - Hostility of the Court p2
7203 - Hostility of the Court p3
7203 - Hypnosis
7203 - Identification
7203 - Ignorance of Law
7203 - Immunity p1
7203 - Immunity p2
7203 - Immunity p3
7203 - Impeachment p1
7203 - Impeachment p2
7203 - Improper Comment PART 1 p1
7203 - Improper Comment PART 1 p2
7203 - Improper Comment PART 1 p3
7203 - Improper Comment PART 1 p4
7203 - Improper Comment PART 1 p5
7203 - Improper Comment PART 2 p1
7203 - Improper Comment PART 2 p2
7203 - Improper Comment PART 2 p3
7203 - Improper Comment PART 2 p4
7203 - Improper Comment PART 2 p5
7203 - Improper Comment PART 3
7203 - Improper Question
7203 - Incrimination 1 p1
7203 - Incrimination 1 p2
7203 - Incrimination 1 p3
7203 - Incrimination 1 p4
7203 - Incrimination 1 p5
7203 - Incrimination 2 p1
7203 - Incrimination 2 p2
7203 - Incrimination 2 p3
7203 - Incrimination 2 p4
7203 - Incrimination 2 p5
7203 - Incriminaton Before Grand Jury p1
7203 - Incriminaton Before Grand Jury p2
7203 - Instructions to Jury 1 p1
7203 - Instructions to Jury 1 p2
7203 - Instructions to Jury 1 p3
7203 - Instructions to Jury 1 p4
7203 - Instructions to Jury 1 p5
7203 - Instructions to Jury 2 p1
7203 - Instructions to Jury 2 p2
7203 - Instructions to Jury 2 p3
7203 - Instructions to Jury 2 p4
7203 - Instructions to Jury 2 p5
7203 - Instructions to Jury 3 p1
7203 - Instructions to Jury 3 p2
7203 - Instructions to Jury 3 p3
7203 - Instructions to Jury 3 p4
7203 - Instructions to Jury 3 p5
7203 - Instructions to Jury 4 p1
7203 - Instructions to Jury 4 p2
7203 - Instructions to Jury 4 p3
7203 - Instructions to Jury 4 p4
7203 - Instructions to Jury 4 p5
7203 - Instructions to Jury 5 p1
7203 - Instructions to Jury 5 p2
7203 - Instructions to Jury 5 p3
7203 - Instructions to Jury 5 p4
7203 - Instructions to Jury 5 p5
7203 - Instructions to Jury 6 p1
7203 - Instructions to Jury 6 p2
7203 - Instructions to Jury 6 p3
7203 - Instructions to Jury 6 p4
7203 - Instructions to Jury 6 p5
7203 - Instructions to Jury 7 p1
7203 - Instructions to Jury 7 p2
7203 - Instructions to Jury 7 p3
7203 - Instructions to Jury 7 p4
7203 - Instructions to Jury 7 p5
7205 Convictions p1
7205 Convictions p2
7205 Convictions p3
7205 Convictions p4
7205 Convictions p5
7205 Double Jeopardy
7205 Exemption Certificates
7205 Hostility of the Court
7205 Indictment
7205 Information
7205 Intent to Deceive Lacking
7205 Right to Counsel
7205 Trial, Timeliness
7205 Variance
7205 Venue
7205 Willfulness
7206 False Returns 1 p1
7206 False Returns 1 p2
7206 False Returns 1 p3
7206 False Returns 1 p4
7206 False Returns 1 p5
7206 False Returns 2 p1
7206 False Returns 2 p2
7206 False Returns 2 p3
7206 False Returns 2 p4
7206 False Returns 2 p5
7206 False Returns 3 p1
7206 False Returns 3 p2
7206 False Returns 3 p3
7206 False Returns 3 p4
7206 Basis for Allegation of Fraud
7206 Concealment of Assets p1
7206 Concealment of Assets p2
7206 Conspiracy 1 p1
7206 Conspiracy 1 p2
7206 Conspiracy 1 p3
7206 Conspiracy 1 p4
7206 Conspiracy 2 p1
7206 Conspiracy 2 p2
7206 Constitutionality p1
7206 Constitutionality p2
7206 Constitutionality p3
7206 Costs
7206 Disclosure of Returns
7206 Estoppel p1
7206 Estoppel p2
7206 Estoppel p3
7206 Evidence 1 p1
7206 Evidence 1 p2
7206 Evidence 1 p3
7206 Evidence 1 p4
7206 Evidence 1 p5
7206 Evidence 2 p1
7206 Evidence 2 p2
7206 Evidence 2 p3
7206 Evidence 2 p4
7206 Evidence 2 p5
7206 Evidence 3 p1
7206 Evidence 3 p2
7206 Evidence 3 p3
7206 Evidence 3 p4
7206 Evidence 3 p5
7206 Evidence 4 p1
7206 Evidence 4 p2
7206 Evidence 4 p3
7206 False Claims Against U.S.
7206 False Documents p1
7206 False Documents p2
7206 False Statements in Return 1 p1
7206 False Statements in Return 1 p2
7206 False Statements in Return 1 p3
7206 False Statements in Return 1 p4
7206 False Statements in Return 1 p5
7206 False Statements in Return 2 p1
7206 False Statements in Return 2 p2
7206 False Statements in Return 2 p3
7206 False Statements in Return 2 p4
7206 False Statements in Return 3 p1
7206 False Statements in Return 3 p2
7206 False Statements in Return 3 p3
7206 False Statements in Return 3 p4
7206 False Statements in Return 3 p5
7206 False Statements in Return 4 p1
7206 False Statements in Return 4 p2
7206 False Statements in Return 4 p3
7206 False Statements in Return 4 p4
7206 False Statements in Return 4 p5
7206 False Statements in Return 5 p1
7206 False Statements in Return 5 p2
7206 False Statements in Return 5 p3
7206 False Statements in Return 5 p4
7206 False Statements to IRS Agents p1
7206 False Statements to IRS Agents p2
7206 False Statements to IRS Agents p3
7206 Forgery
7206 Grand Jury
7206 Guilty Plea p1
7206 Guilty Plea p2
7206 Immunity
7206 Indictment 1 p1
7206 Indictment 1 p2
7206 Indictment 1 p3
7206 Indictment 1 p4
7206 Indictment 1 p5
7206 Indictment 2 p1
7206 Indictment 2 p2
7206 Instructions to Jury 1 p1
7206 Instructions to Jury 1 p2
7206 Instructions to Jury 1 p3
7206 Instructions to Jury 1 p4
7206 Instructions to Jury 1 p5
7206 Instructions to Jury 2 p1
7206 Instructions to Jury 2 p2
7206 Instructions to Jury 2 p3
7206 Instructions to Jury 2 p4
7206 Instructions to Jury 2 p5
7206 Instructions to Jury 3 p1
7206 Instructions to Jury 3 p2
7206 Instructions to Jury 3 p3
7206 Instructions to Jury 3 p4
7206 Instructions to Jury 3 p5
7206 Jury Verdict Disregarded
7206 Jury p1
7206 Jury p2
7206 Jury p3
7206 Lesser Included Offense p1
7206 Lesser Included Offense p2
7206 Motion For Continuance
7206 Motion to Sever
7206 Motion to Transfer
7206 Motion to Vacate Sentence
7206 Net Worth Statement
7206 Offer in Compromise
7206 Perjury
7206 False or Fraudulent Returns p1
7206 False or Fraudulent Returns p2
7206 False or Fraudulent Returns p3
7206 False or Fraudulent Returns p4
7206 False or Fraudulent Returns p5
7206 Prior Convictions
7206 Prior Law
7206 Probation
7206 Prosecutor's Comment p1
7206 Prosecutor's Comment p2
7206 Restitution
7206 Right to Counsel p1
7206 Right to Counsel p2
7206 Sentence p1
7206 Sentence p2
7206 Sentence p3
7206 Sentence p4
7206 Sentencing Guidelines 1 p1
7206 Sentencing Guidelines 1 p2
7206 Sentencing Guidelines 1 p3
7206 Sentencing Guidelines 1 p4
7206 Sentencing Guidelines 1 p5
7206 Sentencing Guidelines 2 p1
7206 Sentencing Guidelines 2 p2
7206 Sentencing Guidelines 2 p3
7206 Statute of Limitations p1
7206 Statute of Limitations p2
7206 Venue
7206 Willfulness Defined p1
7206 Willfulness Defined p2
7206 Willfulness Defined p3
7206 Willfulness Defined p4
7207 Conviction
7207 Defenses
7207 Motion to Dismiss
7207 Sentencing
7207 Willfully Defined
7210 Willful Failure to Obey Summons
7212 Assault
7212 Bribery
7212 Constiutionality
7212 Indictment
7212 Interference p1
7212 Interference p2
7212 Interference p3
7212 Interference p4
7212 Jury Instructions
7212 Rescue of Seized, Levied Property p1
7212 Rescue of Seized, Levied Property p2
7212 Sentence p1
7212 Sentence p2
7212 Statute of Limitations
7212 Suppresion of Evidence
7215 Constitutionality
7215 Conviction
7215 Corporation
7215 Defenses
7215 Evidence
7215 Intent
7215 Speedy Trial
7216 Consent
7216 Preparer Defined
7216 Scope of Statute
7217 IRS Employees

 

Bank Records and Net Worth Increases 5 Page2

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Finding as we do that an essential element of the proof necessary to take this case to the jury on the available funds and expenditures method was lacking, and that the Court's charge incorrectly presented this theory of proof to the jury, we must reverse the judgment below and remand it for a new trial.

REVERSED AND REMANDED.

1 See discussion of this point in Daniel Smith v. United States , supra.

2 Under the heading "The Government's Investigation of Leads," the Supreme Court in the Holland case says: "While sound admin istration of the criminal law requires that the net worth approach--a powerful method of proving otherwise undetectable offenses--should not be denied the Government, its failure to investigate leads furnished by the taxpayer might result in serious injustice. It is, of course, not for us to prescribe investigative procedures, but it is within the province of the courts to pass upon the sufficiency of the evidence to convict. When the Government rests its case solely on the approximations and cricumstantial inferences of a net worth computation, the cogency of its proof depends upon its effective negation of reasonable explanations by the taxpayer inconsistent with guilt. Such refutation might fail when the Government does not track down relevant leads furnished by the taxpayer--leads reasonably susceptible of being checked, which, if true, would establish the taxpayer's innocence."

3 Compare the case of William C. Bostwick v. United States of America, 5th Circuit, decided by us January 20, 19 55 [55-1 USTC ¶9170], in which the Government gave full credit to assets claimed by the accused in his extra-judicial statement to the agents.

4 Although the work performed by accused first as a hotel porter and later as a locker room attendant in a large country club does not of itself bespeak a life of luxury, the testimony of the accused and his wife in which she told of doing both household work and later beauty treatments at the homes of the wives of the same patrons of the club, as well as that of the substantial citizens who appeared as character witnesses for Dupree, brings his testimony well within the field of plausibility that they could have made very substantial savings, if that had been their aim.

5 "Q. Mr. Weber, before we recessed, I was asking about the $20,000 item in '44. You said you knew about that. Will you tell us what you know about that, please?

A. I don't recall the exact date. It was either in '43 or '44, C. A. Dupree came to any office--

Q. Speak a little louder.

A. I say C. A. Dupree came by my office and showed me two cashier's checks for $10,000 each. And I asked him what the occasion was, and he told me that his wife had saved that $20,000, dating back to his entrance into the army in 1917; that she had saved all of his allotment checks and had added to it income from work as a beauty operator and whatever other work she would perform, until she had accumulated this $20,000; and it was her intentions to establish a Negro orphanage."

6 26 U. S. C. A. §41:

"General Rule.

"The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed or if the method employed does not clearly reflect the income, the computation shall be made in accordance with such method as in the opinion of the Commissioner does clearly reflect the income. If the taxpayer's annual accounting period is other than a fiscal year as defined in section 48 or if the taxpayer has no annual accounting period or does not keep books, the net income shall be computed on the basis of the calendar year."

 

 

[83-1 USTC ¶9299]The United States of America v. Lee Eugene Lenamond

U. S. District Court, No. Dist. Tex., Dallas Div., CR 3-80-073-R, 12/28/82

[Code Sec. 7203]

Criminal penalties: Tax evasion: Evidence: Failure of government to conduct adequate investigation.--The taxpayer's conviction for tax evasion was set aside and his motion for acquittal was granted where the government failed to conduct a full and adequate investigation of the taxpayer's inventory figures and to follow leads that indicated the figures were erroneous. The government's use of the bank deposits-cash expenditures method was inappropriate. The use of the gross profit percentage method would have revealed that the inventory figures were too high and that, consequently, no substantial taxes were due from the taxpayer.

Shirley Baccus-Lobel, Assistant United States Attorney, Dallas, Tex. 75242, Thomas D. Blondin, Department of Justice, Washington, D. C. 20530, for plaintiff. Howard A. Weinberger, Ginsberg & Forman, 820 Hartford Bldg., Dallas , Tex. 75201 , for defendant.

Memorandum Opinion

BUCHMEYER, District Judge:

The defendant Lee Eugene Lenamond, was convicted of income tax evasion for 1973 and 1974. His prosecution was based upon the "bank deposits-cash expenditures" method of proof. 1 Lenamond's motion for acquittal presents this question:

Did the government fail to conduct a full and adequate investigation, and did it fail to follow reasonable leads, concerning the value of Lenamond's business inventory--and, consequently, his business deductions for "cost of goods sold" 2--for the years 1973 and 1974?

Because the government did not conduct a full and adequate investigation and did not follow reasonable leads, despite inventory figures which were truly astonishing, the bank deposits method of proof was not sufficient. Therefore, the motion for acquittal is granted and Lenamond's conviction is set aside.

The Legal Principles. At the conclusion of the government's case, and again at the end of the evidence, the defendant moved for acquittal. Decision on this motion was reserved, and the case was submitted to the jury. Fed. R. Crim. P. 29(b). Following the return of a jury verdict which found the defendant guilty on both counts of tax evasion, the motion for acquittal was timely renewed.

The controlling legal principles concerning the "two traditional indirect methods of proof" used by the government in income tax evasion cases--the net worth analysis and the bank deposits-cash expenditures method--are stated in United States v. Dwoskin [81-1 USTC ¶9416], 644 F. 2d 418 (5th Cir. 1981); United States v. Normile [79-1 USTC ¶9151], 587 F. 2d 784 (5th Cir. 1979); and United States v. Boulet [78-2 USTC ¶9628], 577 F. 2d 1165 (5th Cir. 1978)--and, of course, in Holland v. United States [54-2 USTC ¶9714], 348 U. S. 121 (1954). As discussed in Dwoskin:

"A motion for acquittal must be granted 'when the evidence is such that a reasonably minded jury must have a reasonable doubt as to the existence of any element of the crime.' United States v. Slone, 601 F. 2d 800, 803 (5th Cir. 1979); United States v. Pinner [77-2 USTC ¶9706], 561 F. 2d 1203, 1207 (5th Cir. 1977). In evaluating a claim of insufficient evidence according to this standard, we must consider the evidence in the light most favorable to the government, Glasser v. United States, 315 U. S. 60, 80, 62 S. Ct. 457, 469, 86 L. Ed. 680 (1942), resolving reasonable inferences and credibility choices in support of the jury's verdict, United States v. Henderson, 588 F. 2d 157, 161 (5th Cir. 1979); United States v. Juarez, 566 F. 2d 511, 513 (5th Cir. 1978) . . .

"To prove its case, the government relied upon circumstantial evidence [there, a net worth analysis]. Since circumstantial evidence is to be treated no differently than direct evidence, Holland v. United States [54-2 USTC ¶9714], 348 U. S. 121, 140, 75 S. Ct. 127, 137, 99 L. Ed. 150 (1954), the test for judging the sufficiency of the evidence is the same whether the evidence is direct or circumstantial, United States v. Bright, 550 F. 2d 240, 242 (5th Cir. 1977); United States v. Gomez-Rajos, 507 F. 2d 1213, 1221 (5th Cir.), cert. denied, 423 U. S. 826, 96 S. Ct. 41, 46 L. Ed. 2d 42 (1975)." (644 F. 2d at 420.)

However, in Holland , the Supreme Court warned that the net worth method of proof is "so fraught with danger for the innocent that the courts must closely scrutinize its use" (348 U. S. at 125). This is equally true with respect to the bank deposits-cash expenditures analysis. Accordingly, in Boulet, the Fifth Circuit emphasized that both methods trigger special protections for the accused and particularly careful scrutiny by the courts. 3

"We, therefore, review the record 'bearing constantly in mind the difficulties that arise when circumstantial evidence as to guilt is the chief weapon of a method that is itself only an approximation.' Holland v. United States [54-2 USTC ¶9714], 1954, 348 U. S. 121, 129, 75 S. Ct. 127, 132, 99 L. Ed. 150. The government must prove a full and adequate investigation in a bank-deposits case just as it must in a net-worth case. Holland v. United States, supra. 'Such investigation must establish a guarantee of essential accuracy in the circumstantial proof at trial as an element of the government's burden of proving guilt beyond a reasonable doubt. . . .' United States v. Slutsky, supra, 487 F. 2d at 840." (577 F. 2d at 1168.)

As part of this duty to conduct "a full and adequate investigation in a bank deposits case," the government may not disregard any "explanations of the defendant reasonably susceptible of being checked." United States v. Boulet, supra (577 F. 2d at 1169). As the Supreme Court held in Holland :

". . . When the Government rests its case solely on the approximations and circumstantial inferences of a net worth computation, the cogency of its proof depends upon its effective negation of reasonable explanations by the taxpayer inconsistent with guilt. Such refutation might fail when the Government does not track down relevant leads furnished by the taxpayer--leads reasonably susceptible of being checked, which, if true, would establish the taxpayer's innocence. When the Government fails to show an investigation into the validity of such leads, the trial judge may consider them as true and the Government's case as insufficient to go to the jury." (348 U. S. at 135-36) (emphasis added).

However, a full and adequate investigation is required, not a "universal probe." The government is not required "to perform the impossible" (Dwoskin, 644 F. 2d at 423) . . . or "to bay down rabbit tracks" and "follow a trail that might have led nowhere" (Normile, 587 F. 2d at 786) . . . or to conduct a "bacteriophobic search for error" (Normile, 587 F. 2d at 787).

The government's duty to investigate and to follow leads does apply to omitted or understated deductions--particularly, in this case, to the defendant's inventory and his business deductions for cost of goods sold. This is evident from several cases, 4 including United States v. Hall [81-1 USTC ¶9209], 650 F. 2d 994 (9th cir. 1981), where the Ninth Circuit discussed this very question:

"Inventory Cost: Hall and Uranga argue that the Government's figures did not accurately reflect their inventory cost, and consequently yielded inaccurate figures for 'cost of goods sold.' Appellants point out that the cost of goods sold is part of the Government's calculation of the business's gross profit and directly related to the income of the business. Thus, inventory valuation becomes an essential part of the Government's case.

"When choosing to proceed against a defendant using the net worth or bank deposits methods of proof, the Government assumes a special responsibility of thoroughness and particularity in its investigation and presentation. Holland, 348 U. S. at 135-36 . . . This responsibility imposes the duty to, inter alia, accurately establish the figures upon which the methods are based, and to reasonably investigate leads which may reveal that the defendants properly reported their income . . . Here, both this duty to investigate and the duty to establish figures with reasonable certainty are implicated by the Government's treatment of Hall and Uranga's inventory valuation. In particular, the Government must show that it had followed through on appellant Hall's prior notation suggesting that the inventory figures used by the Government were too high. This is a possible explanation for the apparent unreported income and may not be overlooked by the Government." 650 F. 2d at 999-1000). (emphasis added.)

After a careful review of the evidence in this case (including the evidence concerning the government's investigation and the defendant's inventory), and after applying the legal principles just discussed, this Court is convinced that the Holland protections have been violated--and that, consequently, the conviction based upon the bank deposits method of proof must be reversed.

The Investigation. In July of 1975, Randell Choate, 5 an IRS field agent, began a civil tax investigation of the defendant Lenamond--who owned and operated an auto supply store in a low income area in Dallas, Texas (Choate, p. 136; defendant's Exhs. 3-18). 6 This was the first fraud investigation conducted by Choate (Choate, p. 61).

Over the next 18 months, Choate (sometimes accompanied by other IRS agents) had several meetings 7 with the defendant Lenamond and with the CPA representing Lenamond ( Rob ert Driegert), and completed a bank deposits-cash expenditures analysis. Lenamond was very cooperative in the investigation and, with only one exception, 8 supplied Choate with all of the information he requested--although admittedly Lenamond had no accounting experience or ability, had never "gotten any advice on how to maintain books and records," and kept "crummy" books (Choate, pp. 119, 122). 9

In June of 1976, the investigation was converted to a joint criminal and civil investigation (Choate, p. 82). On October 6, 1976, Choate held the first cirminal investigation meeting with Lenamond--although he did not give any notice of this meeting to the CPA representing Lenamond (Choate, pp. 62-63). Lenamond still continued to cooperate.

The investigation concluded in 1976, and it resulted in a recommendation that Lenamond be indicted on income tax evasion charges for 1972, 1973, and 1974. Although Lenamond had no substantial assets or expenditures that pointed toward substantial unreported income--he lived in a $13,000 house in Pleasant Grove; he had no fancy clothes, expensive cars, jewelry, stocks or bonds, hidden bank accounts, etc.; and he owed money on a loan from his father (Choate, pp. 150-53)--he did withhold cash from his daily business receipts for personal living expenses, for payment of salaries, and for occasional payments of business expenses (Choate, pp. 4-5). And, Choate's bank deposits-cash expenditures analysis, indicated that Lenamond's bank deposits and cash expenditures exceeded his reported gross receipts--specifically, that Lenamond may have had unreported income of $28,631 in 1973 and $29,388 in 1974 ( Rob ert S. Driegert transcript, pp. 33-34; see Govt. Exh. 52). 10

No action was taken on this recommendation for over three years, and limitations ran on the year 1972. Finally, on April 15, 1980--the last day of the limitations period for 1973, and almost five years after the investigation started--the defendant Lenamond was indicted for income tax evasion in 1973 and 1974. The indictment charged that additional taxes of $9,796.00 were due in 1973 and that an additional $12,839.80 was due in 1974; at trial, the government reduced these claims to $6,850.82 in 1973 and $9,233.72 in 1974 (see Govt. Exh. 52).

The Inventory. The only aspect of the government's bank deposits-cash expenditures investigation that is under attack by the motion for acquittal concerns the inventory at Lenamond's auto parts store.

The defendant's 1973 income tax return reported a beginning inventory of $40,884.00 and a year-end inventory of $71,864.00 (Govt. Exh. 2). The defendant's 1974 return reported beginning and ending inventories of $71,864.00 and $97,184.00, respectively (Govt. Exh. 3). However, the defendant's purchases increased only 2% during this two-year period when, according to the tax returns, inventory increased 138%. And, the combined increase in inventory over the two-year period ($56,350) is just slightly less than the amount of unreported gross receipts ($58,000) claimed by the government's bank deposits analysis (see Govt. Exh. 52).

The defendant contends that these "astonishing" inventory figures were "arbitrarily arrived at by Mr. Lenamond in ignornace 11 of the tax effect that inflated inventory figures had on his profit. (If ending inventory is artificially inflated, then profits are artificially inflated as well.)"--and that:

"The figures themselves, comparing ending inventory which increased 138% [in 1973 and 1974] to purchases which increased 2%, sales which increased 13.7%, and cost of goods sold which decreased 12%, would have lead any reasonable investigator to conclude that something was wrong in the ending inventory figures."

The basic facts concerning IRS Agent Choate's investigation of the defendant's inventory--or lack of investigation--are undisputed. Choate determined that the defendant did take inventory yearly, but that he made no itemized inventory list and kept no other inventory records. Accordingly, Choate examined the CPA's work copy of the defendant's 1973 return (Choate, pp. 107-110). The ending inventory was first recorded as $43,480--an increase of less than $3,000 over 1972. However, based upon information given to the CPA by Lenamond, this was changed to $52,278, and then increased a third time, to $71,873. Choate testified:

"Q. And those crossed out parts have the effect of increasing Lee's taxable income dramatically from what had been originally in there, do they not?

"A. Yes, sir, it increases it.

"Q. How?

"A. By causing a larger ending inventory, decrease of goods sold and increases gross profit.

"Q. Any accountant knows that?

"A. Yes, sir.

. . .

"Q. What is the effect of having an ending inventory go from 43 to 71 thousand dollars?

"A. It would be to increase income by like 28 thousand.

"Q. Didn't it ever occur to you, Mr. Choate, that Lee Lenamond might have been telling you the truth when he said he couldn't possibly have made that much money that the reason for it was that he had overstated his ending inventory?

"A. He never told me that he overstated his ending inventory.

"Q. You never looked around for things that might help him only for things that might hurt him, isn't that true?

"A. I just looked at the records he had.

"Q. And those records didn't alert you that something was wrong with the inventory?

"A. It looked like he was having problems determining what the inventory was." (Choate, pp. 108-110) (Emphasis added). 12

Choate also examined the defendant's tax returns for 1973 and 1974 (Govt. Exhs. 2, 3). They revealed that purchases "remained very constant" during this period, increasing about 2% (Choate, pp. 113-14)--but that the year-end inventory increased 138% (from $40,884 in 1972 to $71,864 in 1973 to $97,184 in 1974). This meant that something was drastically wrong with the inventory figures. 13 Choate so testified:

"Q. From here to here purchases went up two percent, right?

"A. Yes, sir.

"Q. Okay. From here to here ending inventory went up 138 percent, can you explain that to the ladies and gentlemen of the jury?

"A. No, sir.

"Q. There is no explanation for it, is there?

"A. I cannot explain it, no, sir.

"Q. At the same time the government says his sales were increasing?

"A. Yes, sir.

"Q. How can his sales be increasing if his purchases are remaining more or less constant and the ending inventory, that is the goods he has left over at the end of the year is increasing a 138 percent?

"A. I don't know, sir.

"Q. It can't happen, can it?

"A. It doesn't appear to, sir.

"Q. Something is wrong, isn't there?

"A. Yes, sir.

"Q. And something is wrong in Lee's favor, isn't it?

"A. It would appear to be." (Choate, pp. 115-16) (emphasis added).

Despite this, Choate made no further investigation. He did not ever ask Lenamond if a mistake had been made about the inventory (Choate, p. 119)--even though he knew that Lenamond had no accounting or bookkeeping experience, had not graduated from high school until he was 22, 14 had no professional help regarding his records, had made frequent mistakes on his bookkeeping and bank deposits, had "crummy books," and had a parts store in such a state of disarry (defendant's Exhs. 3-18) that "there might be some difficulty" in taking inventory (Choate, pp. 119-22, 163).

Choate did ask Lenamond a compound question at the November 5, 1976 meeting: could he "explain why he showed a substantial increase in inventory in 1974 and why his cancelled checks lacked quite a bit equalling his expenses claimed on his return for the year." (Choate, pp. 29-30, 37-38). However, Lenamond answered only the second part of this question:

"A. I believe we asked the question if he had any substantial increase in inventory.

"Q. That was November 5th, 1976, right?

"A. Yes, sir, I believe so.

"Q. And let me read what your memo reflects. 'Lenamond was again shown his 1974 income tax return which reflected a substantial increase in inventory and purchases about 20 thousand dollars in excess of those substantiated by checks. Lenamond stated the figures shown for purchases on the return is correct and anything not substantiated by checks would be cash purchases.' He didn't say a darn thing about his inventory, did he?

"A. No, sir.

"Q. Y'all didn't question him about his inventory when he didn't answer your two part question? You asked him two things, didn't you?

"A. Yes, sir.

"Q. You asked him about inventory and purchases, right?

"A. Yes, sir.

"Q. He answered you about purchases but he forgot to saying anything about inventory?

"A. Yes, sir.

"Q. And you didn't ask him, you didn't follow up, you didn't want to know, did you?

"A. We didn't ask him any other questions, I don't believe." (Choate, pp. 117-18).

Choate conceded during testimony that he "just assumed the [inventory] figures from 40 thousand to 71 thousand to 97 thousand dollars were right"--"notwithstanding all the indications that [he] had that they were wrong" (Choate, p. 133). And, by letter dated June 11, 1976 , Agent Choate reported:

"No inventory sheets are kept by Mr. Lenamond, but the inventory seems proper for the two stores and any attempts by him to claim a lesser amount could be overcome." 15

Even after Lenamond's attorney, Donald J. Forman, advised IRS attorneys on May 28, 1978 that there was an inventory problem--and that the inventory did not appear to be kept at a fair market value 16--there was no further investigation.

Choate did attempt to explain that he accepted the defendant's inventory figures because he had no way to check them: the defendant had no inventory records or lists and "without such records it would be impossible to disprove the stated inventory figures." (Choate, p. 181; Government's Opposition to Defendant's Motion for Judgment of Acquittal, pp. 9-10). 17 However, he admitted that he "probably would" have investigated the inventory figures if the situation had been reversed--i. e., if the ending inventory had decreased from $97,000 to $40,884 in two years--since this would indicate that the taxpayer might be avoiding income taxes by undervaluing inventory:

"Q. In connection with the service as an internal revenue agent have you ever had occasion to check a business that had undervalued its ending inventory?

"A. I don't believe I have sir. I can't remember.

". . .

"Q. Let's just say for a second that instead of the inventory increasing from 40 to 71 to 97 it had decreased from say 97 down to 71 to 47. What would the effect of that have been?

"A. To reduce the increase or it would--it would increase his cost of goods sold and decrease gross profit.

"Q. Wouldn't you be immediately tipped off that something was wrong and wouldn't you investigate that?

"A. I probably would, I don't know, sir.

"Q. Okay. Because it is your job to determine the correct amount of tax, right?

"A. Yes, sir.

"Q. If somebody was decreasing their inventory they might not be paying the correct amount of tax, correct?

"A. That's a possibility.

"Q. It would at least alert your suspicions?

"A. Yes, sir." (Choate, pp. 178-79).

The Holland Consequences. Under these facts and under Holland (348 U. S. 121), the government had a duty to conduct a full and adequate investigation and follow leads to determine whether or not Lenamond's inventory figures were too high. United States v. Hall, 650 F. 2d at 999. The inventory figures were truly anomalous: inventory could not increase 138% in two years, while purchases increased only 2%--particularly at the very time when, according to the government's bank deposits proof, the defendant's sales were increasing by 12%.

IRS Agent Choate knew this and he knew that something was wrong with the inventory figures (Choate, pp. 115-16). 18 He knew that the defendant "was having problems determining what the inventory was" (Choate, p. 110). He knew that the defendant's store was in such a state of disarray that "there might be some difficulty" in taking inventory (Choate, p. 163). He knew that the defendant was not sophisticated and had no professional help with his records and "crummy books" (Choate, pp. 119-22). Despite these "leads" 19--and despite the additional, express "lead" concerning inventory furnished by the defendant's attorney 20--the government simply accepted the inventory figures, without any investigation, "notwithstanding all indications . . . that they were wrong" (Choate, p. 133).

It was possible for the government to investigate the inventory figures, 21 and this would not have been "a rabbit trail leading to nowhere" or "a bacteriophobic search for error" (Normile [79-1 USTC ¶9151], 587 F. 2d 787). Agent Choate could have begun simply by asking the defendant if the figures were too high; he never did so (Choate, p. 119). Nor did Choate interview the employees who helped take the inventory; presumably, both David Lenamond and Ronnie Kelley would have told Choate, as they testified at trial, that the inventory did not increase substantially in either 1973 or 1974. Choate could have learned from the CPA (Murray Hay) that he received such a small amount ($50-60) for preparing Lenamond's tax returns, that he did not verify the figures on them. And, since the defendant had cooperated fully in the investigation, Choate could have even requested that an inventory be taken in 1975 or 1976; this could have indicated whether the reported 1973 and 1974 figures were correct. 22

In addition, Choate could have used an indirect method--the industry gross profit percentage--to check Lenamond's inventory figures. Cf. Bernstein v. Commissioner [59-1 USTC ¶9483], 267 F. 2d 879 (5th Cir. 1959). Specifically, he could have determined the gross profit percentage of similar businesses in the same area and time, with the same merchandising policies--and then applied this percentage to the gross sales of Lenamond in 1973 and 1974 in order to approximate his inventory and his cost of goods sold for these years. 23 The government has used this indirect method in other cases 24--but did not do so here. 25

At trial, the defendant's evidence demonstrated how the industry gross profit percentage might have been applied if the Lenamond inventory figures had been investigated. In particular:

. . . David Lenamond, who had first-hand knowledge of the nature of his father's business, and Jack Stoller, who had expert knowledge of similar businesses in the same area and time, both testified that the appropriate gross profit percentage for the defendant's business was approximately 30 percent or less.

. . . Dr. Kenneth Ferris, the defendant's expert, applied this 30% gross profit percentage to Lenamond's sales in 1973 and 1974 (based upon the government's allegations of gross receipts) in order to estimate the inventory figures and the cost of goods sold deductions.

. . . Dr. Ferris, then testified that, based upon his calculations, the inventory figures were much too high and that, in fact, the defendant overpaid his taxes for 1973 in the amount of $867.10 and underpaid his taxes for 1974 in the amount of $588.24, so that the government owed Lenamond $278.86 for the two year period. 26

Dr. Ferris also testified that the defendant's gross profit margins for previous years ranged from a low of 21.6% to a high of 24.2%--and thus never reached the 30% "industry gross profit percentage" used in his calculations--while, under the government's bank deposits calculations reflected in the indictment, Lenamond would have had a profit margin of 42.5% in 1973 and 40.6% in 1974.

The government does not dispute the fact that this indirect method could have been used to check the correctness of the Lenamond inventory figures. It argues, however, that this percentage method is merely "an estimation technique dependent on correct gross receipts, among other variables, and does not compute specific inventories." But the very method of proof upon which the government prosecuted the case (bank deposits-cash expenditures) is an "estimation technique"--and Holland warns lower courts about "the difficulties that arise when circumstantial evidence as to guilt is the chief weapon of a method that is itself only an approximation" (348 U. S. at 129). United States v. Boulet, supra (577 F. 2d at 1168).

The government also contends that it was not obligated to use the industry gross profit percentage analysis since the defendant admitted that "all deductions" on his tax returns were correct. Yet, IRS Agent Choate never asked Lenamond if the inventory figures were mistaken--even though he knew that the inventory figures were anomalous and that somthing was wrong with them. Therefore, any general statement that deductions were correct did not negate the government's duty to investigate the inventory figures--just as it could have done by various means, including the gross profit percentage method. 27

Finally, the government contests the 30% gross profit percentage used in the calculations by defendant's experts. It argues that the jury could have discredited the testimony of David Lenamond and found that 35% was the correct figure 28--and that cross-examination of Mrs. Sharon Lake Liddy (defendant's second expert) established that a 35% gross profit margin would still result in "a substantial tax due and owing" by the defendant. This argument, too, is erroneous.

The issue is not whether the profit margin was 30% or 35%; it is the total failure of the government to use the industry gross profit percentage to determine if the astonishing inventory figures were too high, or to investigate them in any other manner. and, under Holland, when the government fails to show an adequate investigation, the case should not be submitted to the jury--and, when the government fails to track down reasonable leads, "the trial judge may consider them true and the government's case as insufficient to go to the jury" (348 U. S. at 135-36).

The Conclusions. This is the very type of case contemplated by Holland . 29 The government should have conducted a full and adequate investigation of the astonishing inventory figures, and it should have followed leads which indicated that the figures were erroneous. It did not do so.

Since the investigation was not adequate, this case should not have been submitted to the jury. In addition, since the government did not follow reasonable leads, it is appropriate for this court to accept the defendant's position that a proper investigation--including the use of the gross profit percentage method--would have revealed that the inventory figures were too high and that, consequently, no substantial taxes were due for 1973 and 1974.

Accordingly, the motion for acquittal is granted and the conviction of Lee Eugene Lenamond is set aside. 30

1 ". . . Under this method, all deposits to the taxpayer's bank and similar accounts in a single year are added together to determine the gross deposits. An effort is made to identify amounts deposited that are non-taxable, such as gifts, transfers of money between accounts, repayment of loans and cash that the taxpayer had in his possession prior to that year that was deposited in a bank during that year. This process is called 'purification.' It results in a figure called net taxable bank deposits.

"The government agent then adds the amount of expenditures made in cash, for example, in this case, cash the taxpayer received from fees, did not deposit, but gave to his wife to buy groceries. The total of this amount and net taxable bank deposits is deemed to equal gross income. This is in turn reduced by the applicable deductions and exemptions. The figure arrived at is considered to be 'corrected taxable income.' It is then compared with the taxable income reported by the taxpayer on his return." United States v. Boulet [78-2 USTC ¶9628], 577 F. 2d 1165, 1167 (5th Cir. 1978).

2 A merchant selling goods is entitled to an income tax deduction for his cost of goods sold. Normally, this deduction is computed by adding the beginning inventory to purchases during the year to determine the goods available for sale, and then subtracting the ending inventory. The resulting figure is the "cost of goods sold" and is deducted from the merchant's gross receipts to arrive at gross profit. Other expenses are then deducted from the merchant's gross profit to determine the net profit reportable on his income tax return. Internal Revenue Code §§ 61, 62, and 63.

3 In Holland v. United States [54-2 USTC ¶9714], 348 U. S. 121 (1954), the Supreme Court discussed a number of "dangers" presented by the net worth method of proof, concluding:

"While we cannot say that these pitfalls inherent in the net worth method foreclose its use, they do require the exercise of great care and restraint. The complexity of the problem is such that it cannot be met merely by the application of general rules . . . Trial courts should approach these cases in the full realization that the taxpayer may be ensnared in a system which, though difficult for the prosecution to utilize, is equally hard for the defendant to refute . . . Appellate courts should review the cases, bearing constantly in mind the difficulties that arise when circumstantial evidence as to guilt is the chief weapon of a method that is itself only an approximation." (348 U. S. at 129).

4 See United States v. Keller [75-2 USTC ¶9729], 523 F. 2d 1009 (9th Cir. 1975); United States v. Shavin [63-2 USTC ¶9584], 320 F. 2d 308 (7th Cir. 1963), cert. denied, 375 U. S. 944 (1963); and Beck v. United States [62-1 USTC ¶9227], 298 F. 2d 622 (9th Cir. 1962), cert. denied, 370 U. S. 919 (1962). See also United States v. Fowler, 605 F. 2d 181 (5th Cir. 1979).

5 A transcript of Choate's testimony at trial has been prepared; it will be cited in this opinion as "Choate, pp. --" (although these page numbers will, of course, differ from those in the transcript on appeal).

6 For a period of time beginning in 1971, the defendant owned a second auto supply store in Plano , Texas , which was operated by his son, Nolan Lenamond, but which never made a profit.

7 The meetings included those held on March 17, 1976 , on May 19, 1976 , on October 6, 1976 , on November 5, 1976 and on November 23, 1976 . Choate prepared memoranda of these meetings and, when called to testify at trial, had little independent recollection of the meetings, and had to refresh his memory by reading from the memoranda (Choate, pp. 67-68).

8 Although not relevant to this motion for acquittal, the government did contend that Lenamond promised to provide a "spiral notebook," but never did, and that this constituted evidence of wilfulness. This issue was hotly contested, and was fairly presented to the jury, but Choate did concede that Lenamond "stated consistently that he couldn't find this spiral notebook," and that Choate never had "any evidence or any facts . . . that [Lenamond] destroyed it" (Choate, pp. 123, 163). It was also undisputed that the defendant offered several boxes full of purchase tickets, cash tickets, sales invoices, etc.--containing the same information that had been recorded in the spiral notebook--but that Choate chose not to examine these because it would be too time consuming. In particular, Choate testified:

"Q. You know if you had gone over the spiral notebook there would be nothing in the spiral notebook that wasn't in the seven boxes of purchases or sale tickets, don't you?

"A. There shouldn't be.

"Q. All right. You never even bothered to look at the sales tickets, did you?

"A. I couldn't.

"Q. Why couldn't you?

"A. Because of the time restraints of trying to look at each ticket.

"Q. Mr. Choate, the Government is trying to send this man to jail for ten years, isn't that worth enough of your time to look at those tickets?

"A. It wasn't that time because I wasn't in the criminal investigation." (Choate, pp. 104-05).

9 Lenamond did not testify at trial. However, Dr. Murray--a clinical psychologist who specialized in learning disability disorders and who had examined the defendant--testified that Lenamond had a 6th grade reading comprehensive level and a 7th or 8th grade math comprehensive level; that he made "systematic errors" in simple arithmetic; and that, "in his opinion, Lenamond could not complete IRS tax forms anymore than any 11-12 year old." Lenamond, who was 22 when he graduated from high school, paid a CPA (Murray Hay) $50-60 to prepare his 1972 and 1973 returns and paid a bookeeper (Loretta Holbrook) $25-30 to prepare his 1974 returns.

10 These figures were approximations. In the indictment, they were changed to alleged unreported income of $26,997 in 1973 and $31,016 in 1974. At trial, the government's proof claimed unreported income of $29,838 in 1973 and $31,205 in 1974 (Govt. Exh. 52).

11 The defendant did not testify at trial. His son, Nolan Lenamond--who ran the Plano store and who helped the defendant take inventory--testified that he did not know "that having too high an inventory was going to result in too high of profits."

12 The CPA who made these different entries on the work copy of the 1973 return testified that Lenamond "said he reworked his inventory very carefully and that made a mistake and this was the correct figure"--but the CPA never asked to see the inventory records and never checked the inventory himself (Murray Hay, pp. 19-22).

13 And, it drastically reduced the defendant's business deduction for cost of goods sold, and increased his income taxes, as shown by this partial table used during Choate's cross-examination:

                         1972             1973             1974
Purchases .......      $182,000         $178,000         $187,000
Ending Inventory ..      41,000           72,000           97,000
Cost of Goods Sold ..   183,000          146,700          161,000

 

14 See footnote 9.

15 Affidavit of Howard A. Weinberger, dated June 19, 1980 (submitted with Defendant's Motion to Set Aside Jury Verdict and Enter Judgement of Acquittal).

16 The evidence established that some of the inventory had been valued at the retail sales price or the jobber sales price, instead of cost, but that this was corrected before the 1973 return was filed (see footnote 12 and testimony of Murray Hay and Nolan Lenamond).

17 Another IRS agent who testified at trial as an expert witness ( Oldham ) agreed that something was wrong with the inventory figures, but said there were "no leads he could have followed."

18 The defendant's expert witness, Dr. Kenneth Ferris, testified that any auditor or accountant who did not know that the Lenamond inventory figures were erroneous would have been negligent--and that any reasonable accountant would have investigated the inventory figures as part of an audit.

19 The duty to investigate "leads" is merely part of the government's duty to conduct a full and adequate investigation. Thus, even if the matters just discussed were not considered "leads" under Holland , the government still had a duty--because of them--to investigate the Lenamond inventory figures. See United States v. Boulet [78-2 USTC ¶9628], 577 F. 2d 1165, 1168 (5th Cir. 1978) (the "government must prove a full and adequate investigation in a bank deposits case just as it must in a net worth case"); United States v. Hall [81-1 USTC ¶9209], 650 F. 2d 994, 999 (9th Cir. 1981) (the government had both the "duty to investigate and the duty to establish figures with reasonable certainty" because of the taxpayer's notation that the inventory figures were too high).

20 Contrary to the government's arguments, the attorney's statements about the inventory did constitute a "lead" under Holland (see testimony of IRS Agent Douglas Fortney) . . . it was "timely furnished" since the statement was made more than two years before trial . . . and, as discussed above, it was a "lead reasonably susceptible of being checked." Moreover, the government had a duty to investigate the astonishing inventory figures irrespective of whether the attorney's statements constituted a "lead." See footnote 19.

21 IRS Agents are, in fact, instructed to investigate inventory figures in net worth cases where the taxpayer claims the figures on the return are too high. Paragraph 424.9(4) of the Special Agent's Handbook, 5 CCH Internal Revenue Manual, states:

". . . To resolve this, the investigating officers should try and corroborate the inventory figures shown on the taxpayer's returns by admissions of the taxpayer, statements of employees who took the inventory, copies of inventory records, etc."

Although this instruction applies to the value of inventory in net worth cases, it is just as relevant to the value of inventory in a bank deposits-cash expenditures investigation. United States v. Boulet [78-2 USTC ¶9628], 577 F. 2d 1165, 1168 (5th Cir. 1978).

22 The government contends that "there was no reasonable way [it] could have calculated defendant's ending inventories for the years 1973 and 1974, without his assistance." Yet, since the government did not investigate the inventory figures, it never asked for the defendant's assistance--even though he had cooperated throughout the investigation. See footnote 8.

23 Dr. Kenneth Ferris, the defendant's expert, described this indirect method--and testified that it was appropriate to use it to compute cost of goods sold when inventory records are missing or inaccurate.

24 Apparently, this method was used in the trial in United States v. Normile [79-1 USTC ¶9151], 587 F. 2d 784 (5th Cir. 1979) (Defendant's Response to Government's Opposition to Post-Trial Motions, p. 4). And, paragraph 427.11 of the Special Agent's Handbook, 5 CCH Internal Revenue Manual, states that although the gross profit percentage method "is not a prime method of proof and by itself would be of very little value in criminal cases," this percentage method "is very useful for test checking; for corroborating the results obtained by some other means of proof such as . . . bank deposits . . ." (emphasis added)

25 If the situation had been reversed--i. e., if the Lenamond inventory had decreased from $97,000 to $40,884 in two years--the government could have used the industry gross percentage profit method to determine if the inventory had been undervalued in order to avoid taxes (Choate, pp. 178-79). Cf. Thor Power Tool Co. v. Commissioner [79-1 USTC ¶9139], 439 U. S. 528 (1979).

26 Defendant also presented similar testimony and calculations from another expert witness, Mrs. Sharon Lake Liddy (who had served as an IRS field agent for 5 years).

27 A taxpayer may introduce evidence of his own improperly computed cost of goods sold to show both a lack of a tax deficiency and lack of willfullness in civil and criminal fraud cases. See Jenkins v. United States [63-1 USTC ¶9289], 313 F. 2d 624 (5th Cir. 1963); Lee v. United States [72-2 USTC ¶9652], 466 F. 2d 11 (5th Cir. 1972); and United States v. Kramer, 447 F. 2d 210 (2d Cir. 1971).

28 The 35% figure is not based upon a comparison of similar businesses, but upon "the relationship of the cost of goods sold and gross receipts reported on the 1973 return." Thus, it would be reliable only if the anomalous inventory figures are correct. It was undisputed that the defendant's gross profit margin in prior years never exceeded 24.2% (testimony of Dr. Kenneth Ferris).

29 Compare the investigation in this case with those discussed in United States v. Boulet, supra (577 F. 2d 1165); United States v. Slutsky [73-2 USTC ¶9733], 487 F. 2d 832 (C. A. 1977), cert. denied, 416 U. S. 937 (1974); and United States v. Normile, supra (587 F. 2d 784).

30 Because of this action, it is not necessary to consider the two additional matters raised by the defendant--that a new trial should be granted because of possible jury misconduct and because of alleged errors in the jury charge.

 

 

[55-1 USTC ¶9437]Harry H. Blumberg, Appellant v. United States of America , Appellee

(CA-5), In the United States Court of Appeals for the Fifth Circuit, No. 15146, 222 F2d 496, May 13, 19 55

Appeal from the United States District Court for the Southern District of Florida.

[1939 Code Sec. 145(b)--similar to 1954 Code Sec. 7202]

Criminal prosecution: Tax evasion: Admissibility of evidence: Excessive participation by trial court judge.--In reversing a district court conviction of willfully attempting to evade income taxes for 1946 and 1947, the circuit court held that prejudicial error was committed when the district judge participated too much in the trial and when he admitted evidence of prejudicial nature which showed only expenditures, after the government had stated that it would rely upon the "specific omissions" theory of guilt. It was also error when the judge then refused to instruct the jury upon the taxpayer's theory, supported by certain evidence, that such expenditures were made from prior accumulated capital, rather than from current income. The district judge was found to have asked "too many questions" and to have made "too many interruptions", with the result that the jury must have considered him "as interested in the case on the side of the prosecution." It was not material to the theory on which the case was tried to introduce evidence having to do with moneys taken by taxpayer's wife to New York and with large expenditures made by them in launching an elaborate wedding party in a New York hotel to celebrate the marriage of their daughter to the son of a prominent New York banker. The circuit court also held, however, that taxpayer's books and records had not been secured from him in violation of his constitutional rights, and that the district judge had properly ruled that the quality of the accounting services furnished to taxpayer during the two years in question was not a proper matter for opinion evidence.

Claude Pepper, Arthur B. Cunningham, Philip T. Weinstein, Miami , Fla. , for appellant. Vernon W. Evans, Jr., Assistant United States Attorney, Tampa , Fla. , James L. Guilmartin, United States Attorney, Miami , Fla. , for appellee.

Before HUTCHESON, Chief Judge, and DAWKINS, District Judge.

HUTCHESON, Chief Judge:

Convicted of willfully attempting to defeat and evade federal income taxes owing for the calendar years 1946 and 1947, in violation of Section 145(b), 26 U. S. C., defendant, appealing from the judgment imposing a fine of $20,000 and an imprisonment of three years, is here insisting that the trial was attended with prejudicial error and the judgment may not stand.

The government did not rely in this case upon the net worth and expenditures method of proof, and the defendant did not below, he does not here, dispute the fact that for the years in question he did not report the income which the government witnesses testified was received by him in those years and not reported. On the contrary, conceding that there were omissions and that he is civilly liable for the deficiencies caused thereby, he defended below, and defends here, on the ground that the omissions were not willful, and he was, therefore, not guilty of the crimes charged. 1

[Reversible Errors]

In support of his insistence that the judgment must be reversed for the errors assigned, appellant presents six questions for our decision. 2 For the reasons hereafter stated as briefly as may be as to each, we are of the clear opinion: that the first, second, fourth and fifth questions should be answered in the negative, and of the equally clear opinion that the third and sixth questions should be answered in the affirmative; and that these errors were greatly prejudicial and require a reversal.

While appellant has briefed with thoroughness and presented with vigor and apparent confidence each question raised, he has devoted a larger portion of his brief to a discussion of the first, second and third questions, presenting the claimed errors in: (1) holding that appellant's books and records had not been secured from him in violation of his rights under the Fourth and Fifth Amendments; (2) not submitting to the jury under an appropriate instruction, whether they were so secured; and (3) admitting irrelevant but highly prejudicial evidence of expenditures and the refusal of special charges made necessary thereby.

[Production of Books]

We take up the errors presented by the first and second questions to say that we agree with counsel's general propositions, that compulsory production of a taxpayer's books and records for the purpose of use in a criminal prosecution would be violative of constitutional protection against self incrimination, and have many times said so. Cf. White v. U. S. , 194 Fed. (2d) 215 [52-1 USTC ¶9204]. We are convinced, however, that the record, including the testimony of the defendant himself, contains no evidence supporting the claim made on this appeal, that the examinations made of him, his books and records were conducted without his consent, and the books and records themselves were obtained from him not voluntarily but by coercion. On the contrary, we think the record is inconsistent with any other theory than that the defendant voluntarily, indeed without reservations of any kind, discussed the matter of his tax liability frankly and fully with the government agents in an effort to reach an agreement as to, and obtain a settlement of that liability.

It is true that there was no express disclosure made that a purpose in obtaining the evidence was to proceed criminally against him. On the other hand, though defendant had undoubtedly hoped, and may have believed, that no criminal prosecution was intended, there was no representation made to him that the information sought was only for purposes of settling his civil liability. Under these circumstances, we think: that there was no obligation on the agents to inform him that the matters inquired about might be used in a criminal proceeding; that it was no breach of his constitutional rights not to so "inform him" and that the matters propounded as error under this question are not such.

[Opinion Evidence]

Passing the third question for the moment and taking up the fourth, the claimed error in refusing to allow an expert witness to give his opinion as to the character of the accounting services which had been rendered to the appellant during the years in question, we think little need be said about it other than that if the exclusion of the proffered testimony was error, it did not deprive the defendant of substantial evidence making the action prejudicial, and, in the second place, we think the court was correct in ruling that the matter, on which the opinion of the witness was tendered, the quality of the accounting services furnished to appellant during the two years, was not a proper matter for opinion evidence.

When it comes to the fifth question, counsel's statement and argument thereon make it clear that the matters presented under it are more relevant to the general claims of error under the sixth question, the undue intervention of the court in the course of the trial and the prejudice to the defendant arising thereout, than to any particular benefit, of which the claimed restrictions on the particular cross examination had deprived the defendant.

Referring, therefore, to the sixth question, so much of the discussion under the fifth as properly relates to it, and considering the fifth question only as a complaint that defendant was deprived of particular information, we do not believe that a sufficient showing is made of a truly harmful result in the sense of depriving defendant of information to which he was entitled. We do think, though, that treating the interruptions dealt with as matter in point under the sixth general question, they do tend to support the complaint there made.

[Evidence of Expenditures]

Coming now to the third question, whether the admission, over defendant's objection, that it was not material to the theory on which the case was tried, of evidence having to do with moneys taken to New York by defendant's wife and with large expenditures made by them in launching an elaborate and expensive wedding party in a New York hotel to fitly celebrate the marriage of their daughter and the son of a prominent New York banker, was erroneous and prejudicial, we have no hesitancy in saying that it was, and that the erroneous admission was emphasized, exaggerated and made greatly more prejudicial 3 by the refusal of the court to give defendant's requested charges Nos. 15 and 16, or some similar charge.

The government's attempted avoidance of the error of admitting this highly prejudicial evidence by the statement that the evidence was not offered to prove that these expenditures were of money which had not been reported by defendant or that they represented the concealment or evasion of income tax on income over and above the amounts testified to and admitted by the defendant as proper deficiencies, but that they were admissible on the issue of willful intent, does not mitigate, indeed it greatly aggravates the error and resultant injury.

Under the theory upon which the case was tried, that specifically accounted for income had been reported, a theory which the defendant himself conceded to be true, no legitimate purpose could have been served by the proof that the defendant's wife took to New York in a hand satchel $30,000 in cash and deposited part of it in the bank of the man whose son was marrying her daughter, and that they had a tremendous wedding in one of the big hotels in the town at the cost of many thousand dollars. With that evidence before the jury, and no corrective charge given in respect of it, there was no possibility of defendnat's securing an unprejudiced consideration by the jury of his claim that the omissions were due to oversight rather than intention. In addition, with no instruction given them in the matter, the jury is bound to have thought that this money was additional income which had been concealed and not reported.

The government points, as precluding that conclusion, to a statement in the record made by it, that it was not claiming that this was additional income because it couldn't prove it. This statement, however, when taken in connection with the argument of the United States Attorney about the wedding and the money spent, 4 made the matter more greatly prejudicial because the jury, without adequate instruction, could well have taken it upon themselves to say, "Well, whether the government can prove where it came from or not, we know it was hidden and unreported money, and we are going to convict the defendant because of it." Subject to this objection, also, is the testimony that on that trip, part of the money that was taken up, $10,000, was loaned by the wife to defendant's brother-in-law.

It was error to admit the evidence, it was error to refuse the charges, and for these errors the judgment must be reversed.

[Trial Judge's Actions]

As to the sixth specification of error, it is sufficient to say that, while the judge gave a fair charge and generally conducted the trial of the case with care and patience, it is quite plain that he did participate too much in its trial, he did ask too many questions, he did make too many interruptions, and that things said and done by him must inevitably have had the effect, to an extent at least, of having the jury consider him, as was in effect said by another United States Attorney in another case, as interested in the case on the side of the prosecution. Cf. Steele v. United States , 5th Cir., [55-1 USTC ¶9438] this day decided.

We do not say that a district judge must ask no questions and must never take an active part in the eliciting of testimony. It is certainly true, though, that a judge must not only be impartial and disinterested, but must also appear so.

Finally, it is far better for the trial judge to err on the side of abstention from intervention in the case rather than on the side of active participation in it, especially when the major part, if not all of his interruptions and interventions, though by chance rather than by design, are, or seem to be, on, or tending to be on, the side of the government. 5

The judgment is REVERSED and the cause is REMANDED for further and not inconsistent proceedings.

1 This is how appellant states the matter in his brief:

"The evidence upon which the appellant was convicted consisted of proof of the receipt by the appellant in 1946 and 1947 of certain monies from the sale of fruit and for the rental of property, which monies had not been reported as income in his 1946 and 1947 income tax returns and/or those of his wife for the same years. The returns themselves were prepared by a firm of public accountants upon information submitted by appellant's bookkeeper.

"The appellant's defense was that he had never, at any time, intended to defeat or evade his income taxes for the years in question; that he thought that he had given a deposit slip or other memorandum of all payment of money to his bookkeeper; that he had hired outside accountants to check the work of his bookkeeper; that no entries had been made in these books by appellant; that not one witness, including appellant's bookkeeper and accountants, had ever been told to hide, conceal, falsify or omit any of appellant's financial transactions; that the use of cash was customary in appellant's type of business; that appellant's bookkeeper and accountants, by their own admissions, made numerous errors in the appellant's books; that appellant's bookkeeper had actual knowledge of certain receipts of money which she had not entered into the books of appellant in the belief that such receipts were being reported directly to appellant's accountants; and that appellant's bookkeeper would not have known how to enter a cashed check on the books of the appellant."

2 "First Question: Did the Court err in holding that appellant's books and records had not been secured from him in violation of his rights under Amendments IV and V to the Constitution?"

"Second Question: Where the trial court admitted conflicting evidence as to whether or not appellant's books and records had been obtained from him in violation of his constitutional rights, did the trial court err in refusing to give the jury an appropriate instruction, when requested by appellant, permitting the jury to reject and evidence found to be so obtained?"

"Third Question: In a trial for the felony of tax evasion, where the government stated that it would rely upon the specific omissions theory of proof in establishing its case, was it error for the trial court (1) to admit evidence of a peculiarly prejudicial and inflammatory nature which showed only expenditures, and then (2) to refuse to instruct the jury upon appellant's theory, supported by adequate evidence, that such expenditures were made from prior accumulated capital rather than from current income?"

"Fourth Question: Did the trial court err in refusing to allow an expert witness--who had heard all of the evidence adduced at the trial, and who had been appellant's accountant prior to and subsequent to the years charged--to testify as to the accounting services which had been rendered to the appellant during the years charged?"

"Fifth Question: Did the trial court err in unduly restricting appellant's counsel in his cross examination of the government agent who was chief prosecution witness?"

"Sixth Question: Did the trial court err (1) by participating excessively during the trial of the case in a manner which was prejudicial to the appellant, and (2) by interrupting one of appellant's counsel during the close of his summation to the jury and erroneously attributing to such counsel a mis-statement of a material fact?"

3 Hartman v. United States , 215 Fed. (2d) 386 [54-2 USTC ¶9522] and our cases of Jones v. United States, 164 Fed. (2d) 398 [47-2 USTC ¶9402] and Ford v. United States, 210 Fed. (2d) 313 [54-1 USTC ¶9233].

4 "Now in regard to this wedding up in New York . A man is entitled to have any kind of a wedding he wants to for his daughter. He can spend $8500 or $85,000. That's his business. But it no longer remains his business when he has to do it by committing fraud on his government, because those were all concealed transactions; carrying currency in a bag; that was concealed for a purpose, because he didn't want anybody to know that he had that money. Now, if he spent $8500 on a wedding, or, it don't make any difference what he spent, but it was money that was income that should have been reported on his books from all the reasonable inferences that can be drawn from the evidence. The reason it was introduced in evidence here became material because it was paid out of the New York bank account. The New York bank account was admitted in evidence as showing large dealings in large sums of currency with no explanation of its source, so it was admissible in evidence. Then the hotel bill at the Waldorf Astoria, the wedding party bill was admitted in evidence because it showed on its face that they had received $1000 and $8000 payments, and on the New York bank account ledger sheet is an $8000 check, corresponding in time to $8000 payment to the hotel. So they are tied in together. So they are tied in together and therefore the wedding bill was admitted in evidence."

5 Gomila v. United States , 146 Fed. (2d) 372; and Adler v. U. S., 185 Fed. 464-472, Hunter v. U. S. , 62 Fed. (2d) 217, 220, Williams v. U. S. , 93 Fed. (2d) 685, Berkovitz v. U. S. , 213 Fed. (2d) at 470-71-72 [54-1 USTC ¶9425], cited and discussed in it.

 

 

[52-2 USTC ¶9540] United States of America v. Mechael Caserta, Appellant

(CA-3), In the United States Court of Appeals for the Third Circuit, No. 10,817, 199 F2d 905, November 21, 19 52

Appeal from the United States District Court for the Eastern District of Pennsylvania.

Criminal penalties: "Expenditure method" of reconstructing income: Procedure.--Taxpayer was convicted by a jury on charges of filing false and fraudulent income tax returns for 1948 and 1949 under Code Sec. 145(B). He had kept no records and his income was reconstructed by the "expenditure method." In denying a new trial, the District Court held that the method employed was proper and that there was no error in the trial procedure. The court, however, held that the "expenditure method" was inaccurate, since both cash withdrawals and cash purchases were added to income and, presumably, the same items may have been included twice. The court also held that the reading, against the taxpayer's objection, of portions of his selective service question-naire was reversible error. Taxpayer's objections to the insufficiency of the evidence, the denial of his expert witness's testimony, the disallowance of sufficient cross-examination of the government's witness, the allowing of evidence of taxpayer's other offenses, and the denial of a bill of particulars were without merit. Accordingly, the District Court's decision was reversed and remanded.

Jacob Kossman, 1325 Spruce Street , Philadelphia 7, Pennsylvania , for appellant. Thomas J. Curtin, Assistant United States Attorney , U. S. Courthouse, Philadelphia 7, Pennsylvania .

Before MARIS, GOODRICH and STALEY, Circuit Judges.

Opinion of the Court.

By GOODRICH, Circuit Judge.

This is an appeal from a conviction for income tax evasion under 26 U. S. C. §145(B). 1

I. The prosecution was confronted here with a situation not unusual in income tax prosecutions. If the taxpayer had done what he was legally required to do, keep a record of his income and expenditures, the case would be comparatively easy. The question then would be the accuracy of the records kept. The taxpayer here involved kept no records. How is his violation of income tax obligation to be proved? 2 In the effort to ascertain a non-bookkeeping taxpayer's liability, many cases have discussed the requirements which must be met on the so-called net worth theory. 3 This theory is in effect that if a taxpayer's net worth has increased during a given period in an amount greater than his reported income for that period, there must be a discrepancy in his income tax return and payment.

An outgrowth of this net worth method is the "expenditure" test involved in this case. The theory of it is simple, though its application may become difficult. It sharts with an appraisal of the taxpayer's net worth situation at the beginning of a period. He may have much or he may have nothing. If, during that period, his expenditures have exceeded the amount he has returned as income and his net worth at the end of the period is the same as it was at the beginning (or any difference accounted for), then it may be concluded that his income tax return shows less income than he has in fact received. Of course it is necessary, so far as possible, to negative nontaxable receipts by the taxpayer during the period in question. The cases show, however, a rather surprising rule that when the discrepancy between increased net worth and reported income is shown, the burden of explanation shifts to the taxpayer, at the same time repeating the usual criminal law rule that the burden throughout a criminal case is upon the prosecution. 4 We do not, however, get into this particular ramification in the case under discussion, for the prosecutor offered proof negativing receipts for nontaxable sources such as gifts, inheritance and so on. 5

The expenditure method of proof of income received judicial approval in United States v. Johnson, 319 U. S. 503 [43-1 USTC ¶9470], 517 (1943). We think that with this case as a foundation some of the vacillation apparent in Courts of Appeals opinions 6 with regard to proof in tax evasion cases should now be disregarded.

[What Constitutes Expenditure]

What constitutes expenditure? The natural answer is: What a man spends, of course. How does one show expenditures? If a man has a bank account and puts everything he receives into the account, his expenditures are pretty well shown by what he spends it for in checking it out. But suppose he withdraws from his bank account a sum in cash, a check made payable to himself or an impersonal payee. Does that show expenditure? It may well do so if we proceed on the ordinary assumption that people do not draw money from bank accounts unless they are going to spend the money for something. On the other hand, suppose a man writes a check to "cash" for $500. and the same day buys an overcoat for $100. and a suit of clothes for the same amount. Now what do we charge him with, an expenditure of $700.? If cash withdrawals from a bank account are to be treated as cash receipts to a person, surely it is incorrect to charge individual items for which he has paid cash to his list of expenditures unless it is shown that the cash bank withdrawals had nothing to do with the individual items. Otherwise, a man doubles his taxable income when he writes a check for "cash" and spends the money he gets from his bank. This would be a very happy way of increasing one's income if it could be done.

[Withdrawals and Purchases Charged]

All of this seems so obvious that we have had difficulty in believing that the government's case proceeded on a different theory here. But the record does show that this defendant was charged, in the evidence tending to show what his income was, with both cash withdrawals and cash purchases. It was not shown that the cash withdrawals did not go for cash purchases. 7 Furthermore, it is denied, even on appeal, that this was an incorrect method.

The trial judge told the jury that they must not duplicate items. We do not think this is enough in the case at bar in view of the testimony just quoted.

[A Fundamental Error]

What has just been said demonstrates such fundamental error that defendant is entitled to a new trial.

II. Defendant in the court below and again here presses the point that the evidence is not sufficient to sustain a conviction. With this we disagree. A verdict of guilty was sustainable if the jury believed the prosecution's witnesses and disbelieved those of the defendant.

[Expert Testimony]

III. The defendant also complains that he was not allowed to produce an expert witness to controvert the expert witness for the Government. The decisions have gone a great distance in allowing expert witnesses to aid a jury in these prosecutions for income tax violations. 8 The reason is pretty clear. By their very nature and cases are full of complicated figures. An expert's testimony helps the jury understand the problem even though the final responsibility for answering the questions involved remains with them. 9

But if the government is to be permitted to endeavor to establish a taxpayer's criminal responsibility through expert testimony, the privilege of combatting that testimony by expert testimony on his side is open to the defendant. This is a matter of common fairness and common sense. The difficult question is the initial one, namely, whether the subject is a suitable one for expert testimony. That being decided affirmatively, it follows that, as in other cases, the testimony of one expert may be matched against that of another.

The defendant's proffer of his expert was calculated to confuse the judge. He offered the expert for a number of purposes and certainly among them was involved a criticism of the government's legal theory. The court properly told counsel that the law of the case was for the judge and not for an expert witness. On the other hand, the defendant was entitled to an expert witness on any points on which the prosecution was entitled to the use of expert testimony. We think it likely that the defendant did not get as much as he was entitled to although repeated reading of his offer and the colloquy which accompanied it still leaves doubt as to the nature and scope of the offer and extent of the judge's denial.

[Cross-Examination Proper]

IV. Defendant complains that his counsel was unduly restricted on a cross-examination of the government's witness. This point was no merit. Good latitude was allowed by the trial judge in the cross-examination which was pressed far beyond the limits of the patience of most human beings whether on a bench or not. The scope of cross-examination is in general subject to the trial judge's discretion although in a criminal case he must be careful not to restrict it unduly. There was no such restriction here.

V. Complaint is also made of another ruling in connection with the testimony of the government's expert. He had a memorandum in his hand which he used to refresh his memory while testifying. Counsel for the defendant was refused the right to have the jury see this memorandum. We doubt whether this objection is sufficient on which to found a reversal if that were the only thing there was in the case. A reading of Wigmore, however, will show that the refusal to let the jury see the memorandum was incorrect. It is to be pointed out that this is not an instance of what Wigmore calls "past recollection recorded" in which the memorandum itself is admissible as evidence to prove what is said therein. A writing used to refresh the memory of the witness does not, itself, become evidence for the party whose witness uses the memorandum. His evidence is the testimony which he gives in court. But the memorandum which he uses to refresh his own recollections at the time of testifying is something that counsel for the other side can see upon demand and which the jury is entitled to see for whatever effect it may have upon the testimony given by the witness who has been aided by the document. This is fully discussed in Wigmore on Evidence, Sections 762-765 (3d. ed. 1940).

[Evidence of Other Offenses]

VI. Another complaint of the defendant is that the government introduced evidence of other offenses. This testimony was to the effect that the defendant had paid fines for the violation of state laws on two occasions. The defendant now says that this was erroneous and cites the well-known rule to the effect that a man is not to be convicted of one crime by evidence showing that he has been convicted of another. That was not the reason for the use of the testimony in this case. The prosecution was endeavoring to show what the defendant spent his money for. It might have been theater tickets, it might have been automobiles (as it was), or a boat (as it was) or paying it out to the Commonwealth of Pennsylvania in fines. If part of defendant's income was spent for this purpose the government may show it as part of the picture of defendant's expenditures which it was required to make. 10 There is nothing to the defendant's point.

VII. Defendant claims error in the refusal of the trial judge to compel the prosecution to give him a bill of particulars prior to trial. What has been said by our brethren in the Seventh Circuit applies to the situation here. In United States v. Chapman, 168 F. 2d 997 (7th Cir. 1948) the court pointed out that in a case in which the government proposed to use the expenditure theory, the most that the defendant could be entitled to prior to trial was the fact that the prosecution was to proceed upon this theory. The absence of more particularized information was due to the defendant's failure to keep the records he was required to keep and that fault could not be charged to the prosecution. The same reasoning applies here. The defendant now knows all the government knows about the theory of the case and nothing further regarding the bill of particulars can come into it.

The earlier decisions in this circuit, with regard to bills of particulars in such cases, are predicated upon quite a different factual background. 11 It should be remembered also that the granting of a bill of particulars is largely left to the discretion of the trial judge. 12

VIII. Finally, the defendant complains about the reading, against his objection, of portions of his selective service questionnaire. It is not necessary for us to discuss the purpose for which this evidence was introduced. We will assume that it was relevant testimony if otherwise competent.

This point bothered the trial judge who discussed it in his opinion. See 104 Fed. Supp. 661. The questionnaire involved here contained at the bottom a statement to the effect that the information was confidential except for certain specified uses by the government. 13 We think it is a matter of importance that this assurance to registrants that the information they give is to be treated as confidential should be kept in good faith unless the registrant, himself, consents to its disclosure. It has been uniformly held that a third party cannot compel the production of these questionnaires unless the registrant consents. 14 Now it is true that there is a regulation which permits the disclosure and examination of such information to the employees of the local board, medical advisory board and so on ending up with the phrase "proper representatives of the state director of selective service or the director of selective service, United States attorneys and their duly authorized representatives." 32 Code Fed. Reg. §605.32 (1943), as amended, §1606.32(a)(4) (Rev. 1951).

It is argued from this that since the United States attorney may read a registrant's questionnaire he may introduce it in evidence in a trial in which the United States is the prosecutor. If this were a case involving alleged violation of selective service law we might be forced to accept the argument. The same would be true if a man were being prosecuted for perjury for false statements in his questionnaire. See 32 Code Fed. Reg. §1606.35(a). But this case does not involve either one. It is a trial on an entirely separate matter. Just because the United States attorney can look at a piece of paper and get information from it certainly does not mean that he may bring it into court and show it to a jury in any criminal case. 15 We think it may prove highly injurious to the operation of the selective service system if a registrant's confidential information is to be spread far and wide at the wish of local prosecutors. The admission of the questionnaire in this case was error.

The defendant has made other points on this appeal but we do not discuss them because they are too trivial to be worth it. It is obvious from the foregoing that we are compelled to order a new trial. We do so with reluctance. The government had ample evidence to sustain the conviction. The trial judge conducted the case with great patience in spite of the fact that he was subjected to continuous annoyance by the bad court room manners of the counsel for the defendant.

The judgment of the district court is reversed and the case remanded for further proceedings consistent with this opinion.

1 "Any person required under this chapter to collect, account for, and pay over any tax imposed by this chapter, who willfully fails to collect or truthfully account for and pay over such tax, and any person who willfully attempts in any manner to evade or defeat any tax imposed by this chapter or the payment thereof, shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, be fined not more than $10,000, or imprisoned for not more than five years, or both, together with the costs of prosecution."

2 Under section 41 of the Internal Revenue Code ". . . if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income, the computation [of net income] shall be made in accordance with such method as in the opinion of the Commissioner does clearly reflect the income . . ."

3 Brodella v. United States , 184 Fed. (2d) 823 (6th Cir. 1950) [50-2 USTC ¶9477]; Bell v. United States, 185 Fed. (2d) 302 (4th Cir. 1950), cert. denied 340 U. S. 930 (1951) [50-2 USTC ¶9499]; United States v. Fenwick, 177 Fed. (2d) 488 (7th Cir. 1949) [49-2 USTC ¶9448]; Bryan v. United States, 175 Fed. (2d) 223 (5th Cir. 1949) [49-1 USTC ¶9322], affirmed 338 U. S. 552 (1950) [50-1 USTC ¶9140]; United States v. Chapman, 168 Fed. (2d) 997 (7th Cir. 1948) [48-1 USTC ¶9312], cert. denied 335 U. S. 853 (1948).

4 See Schuermann v. United States , 174 Fed. (2d) 397 (8th Cir. 1949) [49-1 USTC ¶9281], cert. denied 338 U. S. 831 (1950), rehearing denied 338 U. S. 831; cases cited note 3 supra.

5 The prosecution introduced evidence that the defendant had never filed an income tax return prior to 1945, and that he had told the investigating tax agent that he borrowed no money prior to 1944, held no money belonging to others, and received no gifts or inheritance of any kind. Evidence was also introduced to show that defendant claimed his wife and mother-in-law as dependents and that they contributed nothing to defendant's available resources.

6 In United States v. Fenwick, and in Bryan v. United States, note 3 supra, the court stated that when the government relies on increased net worth and expenditures in excess of reported income it must produce evidence that excludes all other possible available sources from which additional funds expended could have been derived. This rule was limited in Bell v. United States , Schuermann v. United States , and Brodella v. United States , supra notes 3 and 4, the courts there being unwilling to impose on the government an "impossible burden of proof" in cases proceeding on the expenditure or net worth theories.

7 In computing the defendant's taxable income the government included the face amounts of checks drawn to "cash" totaling $2,850 during 1948, and $742.60 during 1949. It also included cash payments of $1,900 for a boat, $300 to the Clerk of Court, $783.10 to General Motors, $1,319.98 to the Powell-Gardner Buick Co., and many others. The investigating revenue agent testified that in cases where he had been able to trace the proceeds of a check drawn to "cash" into an identifiable cash purchase, the resulting depulication was eliminated. Where tracing proved impossible, however, and where an analysis of the respective dates and amounts of the checks and cash purchases showed no discernable pattern, duplication was assumed not to exist and both checks and purchases were included. The following are excerpts from the trial transcript:

"Q. (by defense counsel on cross-examination). Can you state for a fact that Mr. Caserta did not use any of these cash withdrawals in payment of the cash expenditures . . . for the years 1946, 1947, 1948, and 1949, wherever they occur?

"A. (by the investigating revenue agent). No, sir, I cannot state that as a fact.

"Q. In your tax assessment or analysis, then, you did not credit the cash withdrawals against the cash expenditures; is that correct?

"A. No, sir.

"Q. Were you able to relate or trace these cash withdrawals to any other cash expenditure not listed by you?

"A. If I didn't list it, Mr. Kossman, I guess I couldn't have traced it to that."

* * *

"Q. Now, in determining his income for the year 1947 did you add the cash payment of $50 fine that he had made, and other cash items, $226.50, $29.75 for his wife, $10. to the church, and I think that is all--$306.27. Did you add that to the $4,800 [checks drawn to cash] in order to arrive at his expenditures; is that correct?

"A. (by another internal revenue agent). That is correct."

8 United States v. Johnson, 319 U. S. 503, 519 (1943); United States v. Augustine, 189 Fed. (2d) 587, 589-90 (3rd Cir. 1951).

9 See Wigmore, Evidence §1923 (3d ed. 1940), cited by this court in United States v. Augustine, supra. In United States v. Johnson, supra, the Supreme Court said that testimony of an expert witness regarding the defendant's income and expenditures did not invade the province of the jury where all the evidence so testified to was before the jury and the jury could not have been misled into thinking they had to accept such testimony as determinative of the issue of tax liability.

10 In general see Wigmore, Evidence, §§ 215, 216 (3d ed. 1940). As applied to prosecutions for income tax violations see O'Brien v. United States, 51 Fed. (2d) 193 (7th Cir. 1931) [1931 CCH ¶9474], cert. denied 284 U. S. 673; Capone v. United States, 51 Fed. (2d) 609 (7th cir. 1931) [2 USTC ¶786], cert. denied 284 U. S. 669; United States v. Commerford, 64 Fed. (2d) 28 (2d Cir. 1933) [1933 CCH ¶9255], cert. denied 289 U. S. 759.

11 In Singer v. United States , 58 Fed. (2d) 74 (3rd Cir. 1932) [1932 CCH ¶9188] we held it error to dismiss defendant's motion for a bill of particulars to explain the allegations in the indictment of unreported "income from partnership" and "other income." The result there was the introduction at the trial of extensive evidence of income not properly attributable to the defendant, with consequential prejudice to him even though it was later stricken. Most of the cases require the prosecution to give a bill of particulars to explain an indictment which alleges the source of income, e.g., "sales," "rent," United States v. Hall, 52 Fed. Supp. 798 (D. Conn. 1943), or to explain the fact that the flgures alleged in the indictment do not conform with the defendant's books, United States v. Empire State Paper Corp., 8 Fed. Supp. 220 (S. D. N. Y. 1934). No such elements exist here.

12 Wong Tai v. United States , 273 U. S. 77 (1927).

13 "Family Status and Dependents (Confidential except as to names and addresses)." Information as to earnings is also marked "confidential."

14 4 Moore 's Federal Practice 1168-1169 (1950 ed.); Gray v. Bernuth, Lembcke Co., 8 F. R. D. 358 (E. D. Pa. 1948); Federal Life Ins. Co. v. Holod, 30 Fed. Supp. 713 (M. D. Pa. 1940).

15 5 U. S. C. §139(b)(a) provides that if information obtained in confidence by a Federal agency is released by it to another agency, all the provisions relating to unlawful disclosure of any such information shall apply to all personnel of the second agency.

 

 

[75-2 USTC ¶9654] United States of America , Plaintiff-Appellee v. Charles A. Esser, Defendant-Appellant

(CA-7), U. S. Court of Appeals, 7th Circuit, No. 74-1997, 520 F2d 213, 8/12/75 , Affirming unreported District Court decision

[Code Sec. 7201]

Crimes: Tax evasion: Miscellaneous defenses.--A veterinarian was properly convicted of willfully evading income taxes for three years. An IRS agent was not required to warn him of his Constitutional rights at an interview that was conducted two days before the case was referred to the Intelligence Division. The government was not required to prove the exact date of each offense alleged in the indictment. It was permissible for the government not to introduce, in this bank deposits theory case, all the deposit slips pertaining to the bank account, since it showed that some were unreliable and others unavailable. Moreover, the trial court did not err in permitting the testimony of a summary witness, and it properly refused the veterinarian's instruction regarding bank deposits. The government presented sufficient evidence to prove willfulness and it properly refused to disclose certain survey material.

James R. Thompson, United States Attorney, Gary L. Starkman, Guy P. Seaberg, Assistant United States Attorneys, Chicago, Ill., for plaintiff-appellee. Joel Murray, Rob ert J. Butler, 69 W. Washington St. , Chicago , Ill. , for defendant-appellant.

Before CASTLE, Senior Circuit Judge, BAUER, Circuit Judge, and EAST, Senior District Judge. *

BAUER, Circuit Judge:

Appellant-defendant, Dr. Charles Esser, a verterinarian, was indicted on three counts of willful evasion of income taxes for the years 1967, 1968 and 1969 in violation of 26 U. S. C. §7201. 1

I. Were Miranda Warnings Required at the Outset of the Investigation?

In the latter part of 1969, Phillip M. Smith was an auditor in the Field Audit Division of the Internal Revenue Service. On August 26, 19 69 he called Dr. Esser to arrange a meeting at his animal hospital on September 4, 19 69 for the purpose of examining his books and records relative to a tax audit for the year 1967. At that meeting he examined appellant's books and records for the tax years 1967-1968 and observed that the total deposits in Dr. Esser's bank accounts exceeded his stated income for the years 1967 and 1968 by approximately $57,000 in 1967 and $34,000 in 1968. When questioned about the discrepancy, defendant could think of no explanation for the excess deposits.

Some time between September 4, 19 69 and October 1, 19 69 Smith obtained from Special Agent Gorege Stern of the Internal Revenue Service, Intelligence Division, a list of prepared questions which he used in a subsequent interview of Dr. Esser on October 1, 19 69. Although he had never used the form in a civil audit before, he was familiar with the nature of the questions which it contained and knew that the answers to those questions could bring to light any possible, reasonable explanation for the apparent discrepancies discovered on September 4. Smith stated that the information elicited from the use of the form could be utilized in a civil case, and noted that he would have asked most of the questions included in the questionnaire anyway, but employed it to make sure that he didn't forger anything. At the October 1 meeting Dr. Esser told Smith that he had on hand an amount of money acquired shooting dice in 1944 and 1945, but indicated that it was hidden, and its location would not be disclosed. Dr. Esser also stated at this time that the hidden amounts of money were not deposited in his bank accounts. At no time did Agent Smith advise defendant of his constitutional rights.

Smith first referred the case to the Intelligence Division on October 3, 19 69, two days after the interview with Dr. Esser. He was not contacted by any member of the Intelligence Division of the Internal Revenue Service regarding a criminal tax fraud investigation of Dr. Esser at any time prior to that referral. He was first contacted by Special Agent Stewart J. Hoak of the Intelligence Division approximately two or three weeks after the initial referral.

Defendant claims that all evidence relating to Revenue Agent Smith's October 1, 19 69 interview of defendant should be suppressed, because Smith did not give any Miranda warnings to defendant prior to that interview. That interview occurred prior to the referral of defendant's case to the Intelligence Division. The trial court denied defendant's motion to suppress. In our opinion the district judge was correct.

Under this Court's decision in United States v. Dickerson [69-2 USTC ¶9556], 413 F. 2d 1111, 1117 (7th Cir., 1969), Miranda warnings are only required in noncustodial tax investigations "at the inception of the first contact with the taxpayer after the case has been transferred to the Intelligence Division." This was done in the instant case. The first contact with defendant after transfer of the case to the Intelligence Division was Special Agent Hoak's interview of defendant on November 21, 19 69. At the inception of that interview, Hoak advised the defendant of his constitutional rights. Defendant does not challenge the sufficiency of these warnings.

Relying on a footnote in United States v. Habig [69-2 USTC ¶9557], 413 F. 2d 1108 (7th Cir. 1969) appellant suggests that since Agent Smith had some suspicion that a criminal fraud may have been involved he had for all purposes began the criminal investigation thus making Miranda warnings mandatory. We cannot agree since the record discloses no indication of unreasonable delay or collusion between Smith and any Intelligence Agent. Consequently the motion was properly denied.

II. Must the Government Prove the Exact Date of Each Offense Alleged in the Indictment?

Court I of the indictment charged that on or about April 15, 19 68, defendant willfully and knowingly attempted to evade income tax due for the year 1967, by filing a false income tax return. Court II of the indictment charged that on or about April 15, 19 69, defendant willfully and knowingly attempted to avade income tax due for the year 1968, by filing a false income tax return. Court III of the indictment charged that on or about April 15, 1970, defendant willfully and knowingly attempted to evade income taxes due for the year 1969, by filing a false income tax return. Accordingly defendant argues that since the offense charged in each court of the instant indictment is committed at the time the return is filed, and since each count of the indictment specifically charges the date on or about which defendant filed each return, the government must at least prove that each offense charged was committed on or about a date in close proximity to the date charged in the indictment, and on or about a date before the indictment was returned and within the statute of limitations.

With regard to this claim the defendant stipulated that he had filed the returns, and that the Internal Revenue Service had received them. Each of the returns showed on its face that it was dated in April of the year following the tax year, and defendant identified the returns as having been signed by him on the dates indicated. In the absence of any evidence to the contrary, the trial court concluded that the jury could properly infer that the returns were filed on or about the dates charged.

III. In a Bank Deposits Theory Case Must the Government Introduce Into Evidence All of Defendant's Transactions in the Deposit Account?

Appellant argues that the trial court should have granted motions for judgment of acquittal based upon the government's failure to conduct a thorough examination and analysis of defendant's bank deposits. We do not accept appellant's argument and find that the trial judge had sufficient grounds for denial of the motion for acquittal.

I. R. S. Agent Hoak testified that deposit slips and underlying items of deposit are customarily introduced to demonstrate the nature of the deposits. However, in this instance it was virtually impossible to introduce the deposit slips due to their poor quality, unreliability, and unavailability. The government introduced the bank statements and pass books as the most reliable evidence available. Though appellant attempted on cross-examination to establish that the slips and items were capable of retrieval, the question was left as one of fact for the jury.

Defendant argues also that the bank deposits theory requires an analysis of the bank deposit items themselves. He contends that the government's duty to specifically identify and analyze the defendant's deposit slips and the underlying items is mandated by the "bank deposits cases"; and that failure to do so is fatal to the government's case. On examination the authorities reveal no such duty.

These cases establish that the bank deposits theory requires the government to prove that the defendant was engaged in an income producing business and that regular deposits of funds having the appearance of income were in fact made to bank accounts during the course of business. United States v. Lacob [69-2 USTC ¶9616], 416 F. 2d 756 (7th Cir. 1969); United States v. Stein [71-1 USTC ¶9209], 437 F. 2d 775 (7th Cir. 1971); United States v. Morse [74-1 USTC ¶9228], 491 F. 2d 149 (1st Cir. 1974). The total deposits figure serves as the starting point for further analysis of the taxpayer's account. The government must do everything that is reasonable and fair under the circumstances to identify any non-income transactions and deduct them from total deposits. Further, all proper deductions and credits must be subtracted. United States v. Slutzky [73-2 USTC ¶9733], 487 F. 2d 832 (2nd Cir. 1973). However, the government's investigators are not obliged to track down every conceivable lead offered by the taxpayer to justify the non-income designation of a particular item.

After the government proves that deposits having the appearance of income were made the defendant has the burden to explain as far as possible the deposits. With this done the jury is entitled to infer that the difference between the balance of deposited items and reported income constitutes unreported income. 2

The record herein supports the conclusion that a full investigation of various transactions underlying defendant's deposits was conducted, and that all reasonable steps were taken to identify and deduct non-income items such as inter bank transfers and repayment of loans. The evidence showed that defendant admitted to the agents that he deposited his business receipts into his bank accounts. Further, the bank statements introduced into evidence, particularly the statements from the business checking account, showed regular deposits having the appearance of business receipts. The record is replete with testimony regarding the determination and crediting of non-income items to the total deposits. In our opinion the evidence was more than sufficient to support the verdict below.

IV. Did the trial court err in permitting the testimony of a summary witness?

Appellant seeks to attack the testimony of the government's summary witness predicated on the argument heretofore decided; that the deposits proof was insufficient. The nature of a summary witness' testimony requires that he draw conclusions from the evidence presented at trial. In the instant case the record shows that the summary witness relied only upon the evidence received during the trial and that he was available for full cross-examination. Consequently the evidence was properly admitted for the jury's consideration and the judge properly denied defendant's motion.

The use of a summary witness in a bank deposits case was recently reaffirmed by this Court in United States v. Stein, supra. Summary testimony does not allow the witness to invade the province of the jury as defendant argues. In United States v. Doyle [56-1 USTC ¶9553], 234 F. 2d 788 (7th Cir. 1956), the need for and validity of a summary testimony was upheld, so long as:

"The sources from which the figures were obtained and the calculations prepared were in evidence [and the defendant could enjoy] ample opportunity to cross-examine the auditor fully as to all of those details and as to the evidentiary sources from whence they came" 234 F. 2d at 794.

In short, the government proved by clear, reliable evidence that defendant had enormous bank deposits and that after deducting all non-income sources of deposits, the business receipts far exceeded the amounts shown on his income tax returns. This evidence was more than sufficient to support the jury verdict below.

V. Did the government present sufficient evidence to show that defendant willfully engaged in criminal conduct?

Appellant's argument that the government failed to prove an essential part of the charge, i. e., willfulness, lacks merit. Admittedly there was no evidence in this case of the classic indicia of fraud, e.g., duplicate books and hidden accounts. The government however did in our opinion present evidence sufficient to allow the jury to find that defendant engaged in a pattern of understating income for three consecutive years.

Willfulness may be inferred from conduct which would have the effect of misleading or concealing such as a continual pattern of under-reporting income. See Spies v. United States [43-1 USTC ¶9243], 317 U. S. 492 (1942); Holland v. United States [54-2 USTC ¶9714], 348 U. S. 121 (1954); United States v. Bishop [73-1 USTC ¶9459], 412 U. S. 356 (1973). Defendant argues that there must be some type of independent evidence, i. e., dual bookkeeping, secret accounts, testimony as to intent, to prove willfullness and that it cannot be inferred from the defendant's conduct. In general we agree that in almost every case there must be some independent evidence to corroborate the willful intent that is either inferred or shown by the defendant's actions. However, in a case such as this wherein the facts demonstrate a clear intent to mislead over a period of years, where the evidence is overwhelming, we think the jury could reasonably infer that the defendant's actions were willful.

VI. Was the government's survey material that type which must be disclosed under Brady v. Maryland ?

Appellant's arguments regarding the survey of defendant's customers can be broken down into three separate claims. The first is that governmental counsel misrepresented the nature of the evidence at the pre-trial conferences which took place on or about July 1, 1974. The second is that the defendant was prejudiced because the government failed to product xeroxed copies of the customer's responses to the survey. The third is that the government's references to the survey in closing argument was improper because it was not in evidence.

Defendant claims that government counsel misrepresented the results of the Internal Revenue Service customer survey by stating that it showed insignificant discrepancies between the actual receipts and reported receipts. On January 23, 1974 the government filed its statement of compliance with Rule 2.04 listing the documents turned over to the defense. The servey was not turned over, and the government explicitly represented that "it has no material that fits within the scope of Local Rule 2.04(a) 2-6. The government did not turn over the results of the survey because it was its opinion that the material was not favorable to the defense. This opinion was borne out at trial in our hindsight view.

On March 15, 1974 the government made clear in open court that the survey was originally conducted with a specific items case in mind, but that it had been discarded when the proof evolved into a bank deposits case. The government pointed out that it had no intention of using the survey at trial. Further it was stated that the information contained in the survey would be considered 3500 material if the authors of the responses were ever to take the stand. The implication of this was against clear: the survey was not Brady material and thus was not exculpatory to the defendant. These representations were made in response to a motion for discovery by defendant's then attorney, Mr. Warren L. Schmidt. They were a matter of record when defendant's trial attorneys came into the case In addition, Mr. Schmidt had told trial counsel about the survey and was present at trial.

At the conferences which occurred on or about July 1, 1974 , Assistant United States Attorney Nash stated for the second time that the government did not intend to use the survey evidence at trial because it was insignificant to the presentation of the bank deposits case, and because the survey itself would have constituted inadmissible hearsay. Counsel for the defendant understood him to say that the discrepancies which were revealed by the survey were insignificant, an apparent misunderstanding which they imply led to their conclusion that the survey was in fact favorable to the defendant, thus accounting for its elicitation from Agent Hoak on cross-examination.

The defense did not demand that the government turn over the material under Brady or, alternatively subpoena the survey for use in its case in chief. Instead, defendant's counsel chose to elicit the damaging testimony on cross-examination of one of the government's primary witnesses. The only conceivable explanation for this tactic is that counsel made an unfortunate mistake in not apprising himself of the precise nature of the survey results before eliciting it on his client's behalf. However, the government cannot be held responsible for a defense tactic which happens to strengthen the prosecution's case.

Defendant claims that the government failed to provide photo copies of the written responses to the survey. However the record and the supplementary affidavits establish that the survey was tendered and ultimately turned over to the defendant.

At the time the results of the survey were disclosed by Agent Hoak on cross-examination, the government indicated that defendant was welcome to the survey and agreed to produce it in court. At this time counsel for the defendant did not specifically request that the information be turned over.

On the following day of trial, October 18, the government appeared in court with the summary and the letter responses upon which the summary was based. Defendant objected to the government's attempt to introduce this evidence by re-opening the direct examination of Agent Hoak. At this time the government again explained that it had had no intention of using this survey in the presentation of its case, but felt obliged to produce it to offset the adverse inferences which defendant had raised concerning its absence. The court ruled that the government could introduce the survey on rebuttal. Ultimately, however, neither the survey nor the patient responses were introduced into evidence by either of the parties.

In the afternoon of the same day, October 18, defendant's counsel made a "demand" for the survey in court. Counsel for the government indicated that the survey was being copied and would be provided to defendant as promptly as possible. The court suggested at this time that the details of the turnovers be concluded privately by the parties. At an informal meeting which took place outside the courtroom later in the day, the government counsel came away with the impression that defense counsel indicated that he would be satisfied with the summary itself since the information contained in it would simply be duplicative of the information contained in the customer responses. However, counsel denies making this representation in his affidavit. In the evening of the same day, October 18, counsel for the government met with the defendant's attorneys in the reception room of the United States Attorney's Office, where photo copies of the 25 page summary were turned over to the defense.

On Sunday, October 20, defense counsel called Mr. Nash and requested the 450 letter responses. Mr. Nash indicated that it would be impossible to get reproduction of these responses completed on Sunday but that he would attempt to get them copied on Monday. During the course of the next week defense counsel inquired on three occasions outside the courtroom whether the government had had the opportunity to complete the copying process. Mr. Nash indicated that the process was 95% completed and that counsel could pick them up at any time. The copies were not picked up.

The survey was not mentioned or referred to in open court during the entire week of October 21, until late Friday, October 25, during the presentation of motions at the close of all testimony. At that time defense counsel called the court's attention to the fact that the letter responses had not yet been turned over although receipt of the summary itself was acknowledged. The court observed that since the requests for "summary" or "survey" may well have been confused there was no indication that the government was withholding anything intentionally from the defense. The defense did not request that the court order production of the responses at this time, nor had it made such a request for a formal order at any other time during the trial.

It is apparent that all reasonable attempts were made to accommodate the defendant in his less than urgent requests for the survey data. If for some reason undisclosed in this record defendant indeed desired the copies, he could have formally requested an order from the court prior to the close of testimony. His failure to do so gives rise to a strong inference that defendant's "need" for these items was an afterthought.

Defendant's third claim with regard to the survey is that the government's reference to it during the course of closing argument was improper because the survey was not in evidence. The facts do not support this claim. In its closing argument the government restricted its observations to the defendant's opening statement and to the cross-examination testimony of Special Agent Steward Hoak.

In his opening statement defendant's counsel referred to the survey when he represented to the jury that his cross-examination of Agent Hoak would destroy any government attempt to prove a specific item of unreported income. The subject was thus opened up in the first moments of trial. Subsequently, the defense forced Agent Hoak to testify on cross-examination at some length concerning the nature of the survey results. The subject was thus placed into evidence. The remarks of counsel were before the jury and the testimony of Hoak was in evidence, and it was to those statements that the evidence alone that the government responded in closing argument. Government counsel carefully prefaced his references to the survey results by pointing out that they were based entirely on what "Agent Hoak said", and carefully limited his remarks to the evidence already adduced. He did not go beyond that testimony.

Finally, it should be noted that this was not a close case. The unexpected survey testimony certainly did not help the defense, but even without it the evidence was overwhelming that the defendant committed the offense charged. The discrepancies were large, they took place over a period of years, and the defendant failed to explain them. Defense counsel in this case made a tactical decision which did not detract nor contribute to the outcome of the case to any great degree. On this issue at the very most there was a misunderstanding here. The government could not breach its obligations with regard to the survey, when it had no such obligations. Consequently, in our opinion, the trial judge decided the question properly.

VIII. Did the Trial Court Err in Refusing the Defendant's Instruction Regarding Bank Deposits.

Defendant contends that the district court erred in not giving his requested Instruction No. 17 which read:

"The bare fact standing alone, that a man has deposited sums of money in a bank does not prove that he owed income tax on those amounts."

The instruction was refused because the court determined at the instruction conference that it did not accurately reflect the theory of the defense as claimed. In response, counsel stated that his theory of defense was that cash earned, received or accumulated prior to the tax years in question was not income attributable to those years. With some modification, the court drafted and gave an instruction to this effect, in spite of the court's observation that the defendant had failed to put in any evidence of cash received in prior years.

In view of counsel's own statement regarding the nature of his defense, and the "loan repayment" evidence which he introduced, it is apparent that Instruction No. 17 would have been misleading to the jury if given. In the present case, the government had established substantially more than "deposited sums of money standing alone". Furthermore, the defendant's case as presented did not support his claim to the court that the refused instruction embodied defendant's "most elemental and essential theory of defense." The instruction was properly denied.

Accordingly it is the decision of this Court that the conviction should be affirmed.

AFFIRMED.

* The Honorable William G. East, Senior District Judge, District of Oregon, is sitting by designation.

1 26 U. S. C. §7201 states as follows:

"Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payments thereof shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $10,000, or imprisoned not more than 5 years, or both, together with the costs of prosecution."

2 At trial, the government introduced evidence, primarily in the form of bank statements, that defendant made bank deposits of $125,448.44 in 1967, $125,716.85 in 1968, and $155,189.34 in 1969. Excluding all other sources for these deposits and giving defendant credit for all business expenses claimed, defendant's net business profits far exceeded the amount shown on his return:

Year
                  Net Profits Per
                     Government's         Net Profit
Year                     Evidence         Per Return
1967 ....              $48,092.22         $ 6,873.28
1968 ....              $48,913.31         $15,231.41
1969 ....              $56,817.40         $34,595.43


The government also showed that substantial amounts of federal income tax were due on the unreported business profits.

The government explained in detail the method employed to analyze the defendant's bank deposits during the hears in qeustion. Total deposits were determined by examination of the defendant's bank statements. From that total, all interbank deposits, re-deposits of cash, proceeds of inheritance and gifts and all other nontaxable sources of income were deducted.

 

 

[87-2 USTC ¶9422] United States of America , Plaintiff-Appellee v. Amos Davenport , Defendant-Appellant

(CA-7), U.S. Court of Appeals, 7th Circuit, 86-2488, 7/15/87 , 824 F2d 1511, Affirming an unreported District Court decision

[Code Secs. 7201 and 7203 --Result unchanged by the 1986 Tax Reform Act]

Crimes: Tax evasion: Failure to file: Jury selection: Sufficiency of evidence: Instructions to jury.--A steel worker was properly convicted on one count of tax evasion and five counts of willful failure to file. He was properly denied the right to pretrial inspection of the lists of potential jurors. It was sufficient that the public has access to prior jury lists on a monthly basis from the office of the district clerk. Moreover, the evidence was sufficient--bank records showed that he had sufficient income to require the filing of returns, and the filing of three false W-4 Forms in 1980 supported the tax evasion count for that year. Finally, the jury instructions adequately apprised the jury of the defendant's theory that he was innocent because he had relied on advice given by an attorney.

Andrew B. Spiegel, 77 W. Washington, Chicago , Ill. 60604 , for plaintiff-appellee. Anton Valukas, United States Attorney, Sharon Jones, Assistant United States Attorney, 219 S. Dearborn St., Chicago, Ill. 60604, for defendant-appellant.

Before WOOD, JR., POSNER, and MANION, Circuit Judges.

WOOD, JR., Circuit Judge.

Defendant tax protestor, Amos David Davenport, was charged in Counts One, Two, and Three with tax evasion for the years 1980, 1981, and 1982, in violation of 26 U.S.C. §7201 (1982), and in Counts Four through Eight with willful failure to file his tax returns for the years 1980 through 1984, in violation of 26 U.S.C. §7203 (1982). At the conclusion of a jury trial the district court granted defendant's motion for judgment of acquittal on tax evasion Counts Two and Three. The jury convicted the defendant on the remaining counts. 1

Three issues are raised: (1) did the defendant have the right to inspect and copy the records maintained by the district clerk concerning selection of prospective jurors; (2) was the government's evidence sufficient; and (3) was the jury properly instructed.

I. FACTUAL BACKGROUND

The defendant worked full time on an hourly basis for the same steel company for about twenty years. For the taxable years involved, 1980 through 1984, the defendant's annual gross income varied from approximately $28,000 to $33,300. For the prior years for which the defendant was not charged, 1976 through 1979, the defendant filed his tax returns, but for the years involved in this case he did not. In March 1978 when the defendant filed his 1977 federal income tax return he showed some signs of becoming, as he eventually did, a tax protestor. With his return he enclosed a letter to the Internal Revenue Service ("IRS") in which he explained how he was computing his taxes:

Nowhere in the instruction booklet could I find a computation table that ideally conforms to my particular demands. * * * Ex-President Richard M. Nixon and cohorts has had access to such a table apparently, in that he based his taxes on less than one half of one percent .005 percent. * * * This is the formula I am basing my taxes on since the Constitution of the United States of America requires that taxes be levied equal to all.

Based on his self-serving analysis of the Constitution the defendant then requested a refund of $3840.62 from the taxes that had been withheld in accordance with the Form W-4 he had filed with his employer on which he had claimed three exemptions.

Two years later in March 1980 the defendant filed a new Form W-4 on which he merely claimed to be "Exempt" from withholding, which resulted in no federal taxes being withheld by his employer for that year. For some reason the defendant was not satisfied, as manifested two months later by his filing another Form W-4, again claiming to be exempt, and by filing yet another Form W-4 in December of that year on which in addition to his claim of being exempt he advised the IRS that he was a full-time student. In January 1981 he again filed a new Form W-4 claiming 31 allowances, a sizeable number for a full-time student. This reduced the defendant's income tax to a minimal sum. He filed a considerably greater number of Forms W-4 than he did tax returns.

In March 1985 the United States Attorney for the district, as a polite gesture, had hand delivered to defendant's home a letter that advised the defendant and his wife that the grand jury was very interested in their tax paying behavior and suggested that they file tax returns. The defendant's response was not considered by the United States Attorney to be adequate. The defendant advised the United States Attorney that prior to receiving the government's letter he and his wife had done a lot of research and studying on the subject of income tax and that they were continuing their research. Perhaps that "studying" was what the defendant had reference to when he claimed to be a full-time student. In any event he got himself indicted.

At trial an IRS Revenue Agent, Richard Lexby, testified as an expert witness in determining income and computing the resulting income tax liability. His testimony established that the defendant was required to file tax returns for the pertinent years because the defendant's gross income exceeded $6400. Revenue Agent Lexby explained that the defendant's gross income filing requirement of $6400 was computed by adding the exemption allowed for a married couple filing jointly to the individual exemptions for the defendant, his wife, and his daughter.

The defendant did not testify in his own behalf. Only one witness did, John Hyde of Hammond, Indiana, who described himself as a businessman and an Illinois and Indiana lawyer, but who had practiced only off and on since 1952. In general Mr. Hyde testified that he and the defendant attended various meetings sponsored by Citizens for Just Taxation during 1980, and thereafter he conversed with the defendant about tax law. His theory, as Mr. Hyde said he explained to the defendant, was that the income tax is a tax on net receipts after deduction of all expenses, and that wages were therefore not income. Further, he advised the defendant that the tax laws did not apply to him, but only to those working for the government or to officers in corporations. In addition Mr. Hyde stated to the defendant that 98 percent of federal reserve notes are "bogus." The defendant liked what he heard. However, on cross-examination Mr. Hyde admitted that he also advised the defendant that there were cases that had held to the contrary, that wages were income and that the defendant risked criminal prosecution if the defendant followed his advice. At least that much of Mr. Hyde's advice to the defendant was absolutely correct. 2

II. ISSUES

 

A. Jury Lists

The defendant sought the right prior to trial to inspect and copy all the records maintained by the district clerk concerning the selection of prospective jurors pursuant to section 1867(f) of the Jury Selection and Service Act ("Act"). 28 U.S.C. §§1861-1869 (1982). 3

The defendant's motion to inspect jury lists without supporting affidavit relied on the authority of Test v. United States, 420 U.S. 28 (1975), and defendant's sixth amendment rights. The defendant sought in particular the completed "Juror Qualification Questionnaires so that a meaningful review of the potential jurors can be conducted by the Defendant." 4 The defendant alleged that the jury selection plan had the effect of systematically excluding from the master lists disproportionate numbers of students, blacks, people with Latin surnames, and citizens who are not registered to vote. As an example defendant claimed that in one Chicago ward in a particular primary election only 103,000 of the 257,000 Hispanics eligible to register to vote had in fact registered. 5 The defendant recognizes the validity of using voter registration lists as a primary source for selecting prospective jurors, but argues that the lists must be supplemented from other sources. The defendant also relies on the general policy statement in section 1861 of the Act that all citizens shall have the opportunity to be considered for jury service in the district courts, and the provisions in section 1863(b)(2) that the plan shall prescribe other sources of names in addition to voter lists where necessary to foster that policy.

We discussed similar issues in United States v. Gometz, 730 F.2d 475 (7th Cir.) (en banc), cert. denied, 469 U.S. 845 (1984). In Gometz we considered the fact that although there was only a 30 percent return to the clerk's office of juror qualification forms mailed to registered voters, the response generated over 4000 qualified people for the jury wheel. Gometz had objected to the small numbers of blacks in the wheel and even argued that persons marked by a certain type of personality, those who are "anti-authoritarian" and therefore would ignore the system, would also be excluded. We held, however, that it is the size of the sample which is significant rather than its ratio to the population from which it is drawn that determines whether the method is satisfactory. The Act, we hold, does not require that prospective jurors be conscripted to satisfy some rigid and unrealistic formula.

The jury plan for the Northern District of Illinois does have a provision in compliance with the Act that at such time as the court may find that the use of other prospective juror sources is necessary to foster the policy of the Act the court may direct that other sources be used. It is left to the court to determine the other sources whenever that need may arise. The defendant, however, is not satisfied because the other possible sources are not identified in the plan itself. The defendant claims that over 20 percent of the persons who are eligible for jury duty are not registered voters and are therefore excluded, thereby making the use of other sources necessary.

Test v. United States , 420 U.S. 28, 30 (1975), holds that a criminal defendant has an essentially unqualified right to inspect jury lists. That brief three-page opinion does not fully resolve the present case although the defendant has attempted to cast his motion in a Test context. The court of appeals in Test had not addressed the issue although the district court had denied the motion to inspect the lists. The Supreme Court remanded the case to give the defendant the opportunity to inspect the jury lists so that he might attempt to support his challenge to jury selection procedures. No documents were involved in Test other than jury lists. Test does not hold that completed juror questionnaires must be made available to defendants in addition to jury lists. Neither party has claimed in the present case that the government had access to the questionnaires, while the defendant did not.

Prior jury lists on a monthly basis are available as a public record in the clerk's office. Defendant has shown no reason why those lists would not be adequate for his purposes. If the system is not working in accordance with the Act's requirement the available lists could be of use in establishing an alleged deficiency. Defendant has not demonstrated why other records besides those available jury lists might be required.

The Act itself, in section 1867(f), provides that the contents of records or papers used by the clerk shall not be disclosed unless those records' contents are shown to be "necessary" for the preparation of a motion to claim, under section 1867(a), that there has been a "substantial failure to comply" with the Act. The defendant has not shown why more is needed than what is already available or why the statutory prohibition of disclosure needs to be breached. Neither has the defendant set forth any "substantial failure to comply." Even if defendant's speculation is correct about those persons who are not adequately represented on the voter registration lists no substantial failure would exist. There is no need to search for and use other sources. Voter lists take in a cross section of the community of sufficient magnitude to satisfy the Act in the absence of some particular circumstance or scheme undermining the worthy purposes of the Act. The defendant claims nothing of that sort, only that the voter registration lists do not have enough names from certain categories, particularly Hispanics. The jury lists already available to defendant could have been used to try to show some substantial Hispanic disparity. Relying merely on names might not always be completely accurate for that purpose, but what was available was not used here.

Defendant is making a claim that appears to us to lack any bona fide basis, a frivolous exploration. What defendant really desires, and what he particularly asked for in his motion, were the juror questionnaires completed and returned to the clerk. Those questionnaires contain prospective jurors' home addresses and other personal information. To give the defendant an absolute right of routine access to all materials would be an amendment of the Act. The defendant may be seeking those forms as an aid for voir dire examination purposes, but that is not the purpose of the questionnaires. If these completed judicial jury forms were released to defendants generally there would exist the possibility of substantial abuse of the information the forms contain, which could have serious consequences for individual jurors and the system. 6

B. Sufficiency of the Evidence

The defendant's motion for judgment of acquittal at the close of the government's case was allowed only as to Counts Two and Three, which were tax evasion charges for the years 1981 and 1982. The district judge found the government's proof insufficient to show that the defendant was not entitled to the 31 allowances the defendant claimed on his new Form W-4 filed in January 1981. 7 However, the district court denied the defendant's motion as to Count One, which was the tax evasion charge for the year 1980. On the Form W-4 filed for that year the defendant claimed to be exempt because he was a full-time student, whereas it was clear he was still regularly employed as he had been for prior years at the steel company.

The defendant claims that the trial judge should also have allowed his motion as to Count One because the Form W-4 in question, on which the defendant claimed to be a full-time student, was dated December 18, 1980 , and was therefore only in effect a few weeks until the end of the year, or no later than January 18, 1981 , at which time the defendant filed a new Form W-4 on which he claimed the 31 allowances. That argument is of no moment because the Form W-4 filed on December 18, 1980, was the third false Form W-4 the defendant had filed for that year and obviously was a part of his scheme to avoid paying taxes for that year.

The defendant also claims that there was reasonable doubt that he had a substantial tax liability for 1980. This argument is based on the claim that he could have been entitled to additional deductions, if itemized, above the standard deduction and that those unknown deductions are hidden in his extensive use of cash. Subtracting the $1538.32 withheld in taxes by the defendant's employer in 1980 Revenue Agent Lexby calculated a tax deficiency owing of $3358.68. Revenue Agent Lexby gave the defendant credit for any possible deductions that could have been itemized.

Our standard of review of a sufficiency of the evidence claim has long been recognized to be that we will affirm the conviction if after viewing all of the evidence, along with reasonable inferences in the light most favorable to the government, there is substantial evidence supporting the verdict, Glasser v. United States, 315 U.S. 60, 80 (1942), or if there is at least some evidence from which a jury could find guilt beyond a reasonable doubt, United States v. Redwine, 715 F.2d 315, 319 (7th Cir. 1983), cert. denied, 467 U.S. 1216 (1984).

It is equally clear that to sustain a conviction for income tax evasion the government must prove beyond a reasonable doubt: (1) an affirmative act constituting an evasion or attempted evasion of the payment or collection of taxes; (2) the existence of a substantial tax deficiency; and (3) that the defendant acted willfully. Sansone v. United States [65-1 USTC ¶9307 ], 380 U.S. 343, 351 (1965); United States v. Foster [86-1 USTC ¶9327 ], 789 F.2d 457, 459 (7th Cir.), cert. denied, 107 S.Ct. 273 (1986).

Defendant contends mainly that the government did not establish the existence of a substantial tax deficiency. Revenue Agent Lexby testified that he analyzed the bank account records of the checking account into which the defendant deposited his steel company paychecks. This analysis revealed the defendant's extensive use of cash. The records showed total deposits of $133,000 from 1980 to 1984 from which well over half was withdrawn by the defendant in the form of checks made out to cash, all in amounts of $100 or more. The defendant also purchased two automobiles and made the car payments all in cash.

In response to Revenue Agent Lexby's analysis the defendant argues that he had some excess unidentified deductions he was entitled to claim which were unaccounted for by Revenue Agent Lexby; but the defendant's argument is all theoretical. The government easily showed the amount of the defendant's wages from his employer. Some cancelled checks were introduced to help substantiate legitimate deductions, an example being the defendant's real estate taxes. This type of legitimate deduction generally may also include such things as medical expenses, charitable contributions, casualty losses, and interest, among others. The defendant's other tax records in evidence showed no claim for excess itemized deductions in prior years. The evidence as a whole was sufficient to preclude any significant possibility that the defendant had excess deductions that he would have been entitled to claim if he had itemized them. His specific deductions were below the standard deduction for which he was given credit.

It is neither necessary nor reasonably practicable to require the government to prove that there are no other conceivable deductions of any sort to which the defendant might be entitled in the absence of some indication that they may in fact exist. To require otherwise would force the government to trace all the miscellaneous payments the defendant had made. If other than theoretical deductions actually existed, the defendant had a self-help opportunity to prove the existence of the deductions, an opportunity he chose not to take. United States v. Lacob [69-2 USTC ¶9616 ], 416 F.2d 756, 759-60 (7th Cir. 1969), cert. denied, 396 U.S. 1059 (1970).

There have been many greater tax deficiencies resulting from tax evasion which we see on appeal, but the little more than $3000 in taxes the defendant evaded paying will amply suffice for the purpose. United States v. Cunningham [83-2 USTC ¶9730 ], 723 F.2d 217, 231 (2d Cir. 1983) (holding additional tax of $2617 to be substantial), cert. denied, 466 U.S. 951 (1984); United States v. Siragusa [71-2 USTC ¶9730 ], 450 F.2d 592, 595-96 (2d Cir. 1971) (holding taxes due of $900, $2209, and $3956 over three years to be substantial), cert. denied, 405 U.S. 974 (1972).

C. Instructions

The defendant lastly complains that the district court improperly instructed the jury on the element of willfulness and on his corresponding defense that he had a good faith misunderstanding of the law. He claims that the district court improperly modified his theory-of-defense instruction. In addition the defendant argues that the district court committed error when it refused to give his lesser-included-offense instruction pertinent to Counts One and Four, arguing that failure to file is a lesser included offense of tax evasion. It is not new law that jury instructions are reviewed as a whole and not merely on the basis of "one single paragraph, sentence, phrase or word." United States v. Lang, 644 F.2d 1232, 1240 (7th Cir.), cert. denied, 454 U.S. 870 (1981).

The jury was fully and correctly instructed on the "willful" requirement as a voluntary, intentional violation of a known legal duty. United States v. Pomponio [76-2 USTC ¶9695 ], 429 U.S. 10, 12 (1976). 8 The defendant did not object to that instruction.

The jury was then instructed on the defendant's theory of his defense to the effect that he claimed to have relied in good faith on attorney Hyde's advice and therefore what he did was not willful. 9 We find no fault with that instruction as it relates to reliance on the advice of an attorney. United States v. Baldwin [62-2 USTC ¶9644 ], 307 F.2d 577, 579 (7th Cir. 1962), cert. denied, 371 U.S. 947 (1963); United States v. Samara [81-1 USTC ¶9220 ], 643 F.2d 701, 703 (10th Cir.), cert. denied, 454 U.S. 829 (1981).

Next, the district judge instructed the jury on the meaning of good faith which causes the defendant to question, as have others, 10 the validity of our decision in United States v. Moore [80-2 USTC ¶9627 ], 627 F.2d 830 (7th Cir. 1980), cert. denied, 450 U.S. 916 (1981). Moore defines our view of a defendant's good faith reliance on an attorney's advice. The advice need not be legally correct, but the defendant must honestly and reasonably believe that the advice was correct and therefore relied on it. The instruction, the defendant argues, in requiring that his alleged misunderstanding of the law be "reasonable," strips the mens rea requirement from the Internal Revenue Code in direct conflict with United States v. Murdock [3 USTC ¶1194 ], 290 U.S. 389 (1933), implicitly overruled on other grounds, Murphy v. Waterfront Commission, 378 U.S. 52, 77, 80 (1964); United States v. Bishop [73-1 USTC ¶9459 ], 412 U.S. 346 (1973); and United States v. Pomponio [76-2 USTC ¶9695 ], 429 U.S. 10 (1976).

We do not read Murdock as requiring instructions different from those given. Murdock was a case in which the defendant declined on the basis of self-incrimination to answer questions when summoned before an IRS agent, and he was therefore prosecuted for willfully failing to supply information. Murdock explains that "willfully" is not used in the revenue acts so that "a person, by reason of a bona fide misunderstanding as to his liability for the tax, as to his duty to make a return, or as to the adequacy of the records he maintained, should become a criminal by his mere failure to measure up to the prescribed standard of conduct." 390 U.S. at 396. As a result the Murdock Court held that the defendant was entitled to the benefit of a good faith and actual belief instruction. In the present case similar instructions were given.

In Bishop it was held that "willfully" means as much when used in a misdemeanor revenue statute as when used in a felony revenue statute. It embodies an element of mens rea, bad purpose, or evil motive, to "separate the purposeful tax violator from the well-meaning, but easily confused, mass of taxpayers." 346 U.S. at 361. We see no serious conflict between the instructions given and the Bishop holding.

Pomponio holds that "willfully" in the revenue code context "simply means a voluntary, intentional violation of a known legal duty." 429 U.S. at 12. In addition it holds that no additional good faith instruction need be given. The defendant in the present case, however, got both.

We have previously considered cases that disagree with Moore, United States v. Phillips [85-2 USTC ¶9745 ], 775 F.2d 262, 264 (10th Cir. 1985), and United States v. Aitken [85-1 USTC ¶9209 ], 755 F.2d 188, 191-93 & n.2 (1st Cir. 1985), which are good expressions of a contrary view. But we again decline for the purposes of this case to abandon Moore . See United States v. Sato, 814 F.2d 449, 451 (7th Cir. 1987); United States v. Thomas [86-1 USTC ¶9354 ], 788 F.2d 1250, 1255 (7th Cir.), cert. denied, 107 S. Ct. 187 (1986). In United States v. Bressler [85-2 USTC ¶9646 ], 772 F.2d 287, 291 n.2 (7th Cir. 1985), cert. denied, 106 S. Ct. 852 (1986), we explained that "[t]he reasonableness requirement is intended to give the jury a method by which they can distinguish between a bona fide misunderstanding of the law and obdurate refusal to acknowledge (present in so many tax protester cases) what the law indeed does require." Id. The jury needs to be able to take reasonableness into account for that purpose.

The defendant also finds fault with the theory-of-defense instruction, which was a modification of the instruction he offered. The modification eliminated misstatements of the law and the excess language that was already covered by other instructions. The jury was instructed that it was defendant's theory that he did not report his income because he was acting upon the legal advice of attorney Hyde. The instructions as a whole fully, adequately, and correctly advised the jury of the law it was to apply.

Even if the defendant's preferred instructions had been given, the jury still would have been entitled to convict the defendant. He had paid taxes on his wages in the past and he knew how to use the Form W-4. It was obvious that the defendant was no full-time student, but at most was a self-described part-time student only studying ways to avoid paying his taxes. His lawyer, upon whose advice the defendant claims he relied, admitted on cross-examination that he advised the defendant that he was running the risk of criminal prosecution if the defendant followed his tax advice. In addition the defendant advised the IRS that he was going to apply the Nixon tax formula, as he saw it, in preference to what he understood to be the formula required by the IRS. He claimed on his Forms W-4 to be exempt, but he was aware that he was not exempt from paying taxes merely because he would rather not pay. His extensive use of cash, a practice common among tax evaders, was not for mere convenience. Moreover, he did receive correct legal advice in a letter from the United States Attorney advising him to pay his taxes to avoid indictment but he ignored that advice to this end.

The defendant also argues that his conviction on Counts One, tax evasion for 1980, and Four, willfully failing to file a return for 1980, should be reversed because the district court refused to give a lesser-included-offense instruction. That refusal was correct because the one is not the lesser included offense of the other. They are separate and distinct offenses and conviction of both does not violate the double jeopardy clause. We have recently so held. United States v. Foster [86-1 USTC ¶9327 ], 789 F.2d 457, 460 (7th Cir.), cert. denied, 107 S.Ct. 273 (1986). The elements are different in each of the separate crimes and the jury was separately instructed as to both offenses which were separately charged. The jury could have found the defendant guilty of neither, one, or both, and it chose both. This distinguishes Sansone v. United States [65-1 USTC ¶9307 ], 380 U.S. 343, 344, 349-50 (1965), because in that case only the greater offense was charged, not both the lesser and the greater.

Defendant's guilt was firmly established before a jury properly instructed. Therefore the defendant's conviction is

AFFIRMED.

APPENDIX

Following is an excerpt from the direct testimony of defense witness John Hyde, a lawyer admitted to practice in Indiana and Illinois :

A. So he [the defendant] said, can you explain it to me, John? I said, well, it will take a little while, you got a half an hour. He said, oh, yeah, take--got a lot of time.

So I told him--oh, he said I have been doing some interesting reading about--in the Bible. He says, Leviticus calls for a system of honest weights and measures or just weights and measures. I don't know which the word was. And he said, you know, also the Bible speak [sic] of money as the fruit of the earth, substances from the earth. And that's why we use gold and silver.

Now, I knew--I said, well you view it from the standpoint, Dave, that the gold and silver are used because they are honest and the politicians can't create them. But I think there is another more significant point about why gold and silver got to be used as money instead of printing press paper.

And I said--he said, what's that? And I said, well, it's the fact that gold and silver from the beginning of history of mankind have been used for trading purposes. And the reason that they have been used for trading purposes is because everbody [sic] knows their value. Nobody questions what an ounce of gold is worth. And that bears on the issue of what is good money, Dave, because money is merely a substitute for some other kind of consideration in a bargain and sale or a trade of any kind.

I says, now, you have got--this is basic, you have got to understand, if you are going to use this defense or use--or act upon this information, Dave, you got to understand the principles.

Everything that people do with each other, all the business they conduct, are essentially trades. And in every trade, the principal [sic] motivating both parties is that they believe they are getting as much from the other guy as they are giving to him.

In other words, what is swapped in every trade is equal in value.

Now, if you are going to substitute money, instead of giving a person a pig for a fur coat, you are going to give him $20 for the fur coat, then that $20 has got to have the same value as a pig. It can't be a chimera, it can't be an illusionary value. It has got to be real solid value. So that's why gold and silver make good money. Because you can substitute them and the guy that takes the gold knows he is getting something just as valuable as anything else he might have gotten in the world. So he makes the deal.

Q. Did you explain to Mr. Davenport how that would affect the question of income tax?

A. Yeah, well, he asked me that question. He says, yeah, but John, that's not the money. How does that affect a person's income tax status? I said, that's basic. Your income tax is a tax not on value, but on excess value. What do you--you mean profit and gain, John? Yes, that's exactly what I mean. An income tax is not a tax on gross receipts. It's a tax on net receipts after deduction of all expenses.

I said, so the question of whether you have received anything, received value that can constitute a profit or a gain, gets right down to the nub of what the heck is value. Money of gold and silver has unquestioned value.

Now, in order to compute profit or gain, you have to compare the difference between two separate transactions, each transaction consisting of an equal exchange.

 

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