Marvin Sherwin v. United States

POPE, Circuit Judge.

The appellant in this case was convicted on all six counts of an indictment which charged him with offenses under 26 U.S.C. (I.R.C.1954) § 7201 and 26 U.S. C. (I.R.C.1954) § 7206(1).

The first three Counts, drawn under § 7201, were substantially identical except that Count 1 charged willful and knowing attempt to evade and defeat a large part of the income tax due and owing by the defendant and his wife for the calendar year 1954; Count 2 made a similar charge with respect to the tax for the calendar year 1955; and Count 3 alleged the attempt to evade and defeat the income…