D'Alise v. Commissioner

OPINION.

Mukdock, Judge:

Vincenzo has not had the benefit of much education. He was not represented by counsel. He stated that he was a bootlegger during prohibition, and thereafter, at least during the taxable years, operated a numbers game. He admits he had accumulated prior to December 31, 1950, about $25,000, mainly by law violations. The Commissioner, in attempting to sustain his burden of proof on the fraud issue, does not rely upon the testimony of Vincenzo before this Court. He relies, instead, solely upon a 15-page document containing mimeographed questions which were put to Vincenzo…