United States v. Joseph F. Schipani

ANDERSON, Circuit Judge:

The defendant-appellant was convicted ■on all five counts of an indictment charging him with, violations of Title 26 U.S.C. § 7201 1 for willfully evading the payment of personal income taxes due from him for the five calendar years 1956 through 1960. He was fined $2500 and sentenced to three years imprisonment on each count, to be served concurrently, but with the proviso that he should not be released from confinement until the fines had been fully paid.

The case was tried on the “net worth” theory, in support of which the Government offered evidence to prove that…