United States v. Dennis Roy Choate

In an August 21,1974 indictment, Choate was charged with income tax evasion for understating his income in 1970 and 1971, in violation of 26 U.S.C. § 7201. The Government intended to offer at trial Choate’s amended returns for those years, which he filed in October, 1972, and documentary evidence tending to prove that Choate’s expenditures were greatly in excess of his originally-reported income.1

Choate moved to suppress “all physical evidence sought to be introduced against him” on the theory that it was tainted by illegal searches of his home conducted by a government informant in 1971.…