United States v. Jose Medardo Alvero Cruz

HATCHETT, Circuit Judge:

In this criminal case, with prosecution under 26 U.S.C.A. § 7201, we must decide whether a jury instruction regarding establishment of a foreign tax credit under 26 U.S.C.A. § 901 was correct. Finding the instruction correct, we affirm.

In May, 1979, a grand jury investigation focused on the appellant, Jose Medardo Alvero Cruz, because information provided by a reliable government source indicated that Cruz was involved with narcotics and tax fraud activities. The investigation led to inquiries in Spain where information showed that Cruz lived a lavish lifestyle and…