United States v. Frank L. Silverman

HAYS, Circuit Judge:

This is an appeal from a judgment of conviction on five counts of attempted income tax evasion (26 U.S.C. § 7201 (1970)), entered in the United States District Court for the Southern District of New York after a jury trial. Appellant was sentenced to one year imprisonment on each count, the sentences to run concurrently. We affirm the judgment of the district court.

The Government’s proof at the trial showed that appellant’s tax returns for the calendar years 1961-1965 substantially understated his taxable income. Silverman is an attorney, whose income consisted principally…