United States v. Sam Achilli

LINDLEY, Circuit Judge.

Defendant appeals from a judgment entered on a jury verdict finding him guilty on three counts of an indictment charging willful evasion of income taxes for the taxable years 1946, 1947 and 1948, in violation of Section 145(b) of the Internal Revenue Code of 1939, 26 U.S.C.

The Government employed what is commonly referred to as the net worth method of establishing deficiencies, proceeding on the theory that increases in the taxpayer’s net worth over that at the beginning of the taxable year, plus nondeductible expenditures, constituted income to the taxpayer during that…