United States v. Ingredient Technology Corporation, Formerly Known as Sucrest Corporation, and Robert M. Rapaport

OAKES, Circuit Judge:

This appeal is by a corporation and its former president from judgments of conviction for tax fraud by means of year-end LIFO (“last-in-first-out”) inventory overstatement. The principal arguments of both defendants before the jury in a trial in the United States District Court for the Southern District of New York, Robert L. Carter, Judge, were that the inventory was not overstated because the corporation in fact had legal title on the year-end date to the property in question — raw sugar — even though it had previously agreed to resell it to its seller, and that in any…