Palermo v. United States

delivéred the opinion of the Court.

• Petitioner was convicted of knowingly and willfully evading the payment of income taxes for the years 1950,' 1951 and 1952. A substantial part of the alleged evasion was failure to report income from dividends. Among the Government’s exhibits at trial was a record, presum-' *344ably contemporaneous and in the petitioner’s handwriting, of dividends received during 1951 and 1952. This record reflected an amount of dividend income for 1951 substantially larger than that reported on the 1951 return. Petitioner contended that this record had-been turned over to the…