United States v. Charles A. Schafer

COLEMAN, Circuit Judge.

Charles A. Schafer appeals from his conviction by a jury on three counts of willful evasion of federal income taxes. 1 The government established its case through the “net worth” approach, a method of circumstantial proof which basically consists of five steps: (1) calculation of net worth at the end of a taxable year, (2) subtraction of net worth at the beginning of the same taxable year, (3) addition of non-deductible expenditures for personal, including living, expenditures, (4) subtraction of receipts from income sources that are non-taxable, and (5) comparison of…