United States v. Ronald M. Long

Ronald M. Long was convicted of willful failure to file income tax returns for the years 1972, 1973 and 1974. I.R.C. § 7203. Long appeals, asserting a failure of proof.

At Long’s nonjury trial, the government contended that it had no record that Long had filed any returns for the years in question. Long responded that he had filed returns and that the government had lost them. In support of this contention, Long introduced “facsimiles” of certain 1040 forms he claimed to have filed. 1 On each of the facsimile forms, Long had inserted zeros in the spaces reserved for entering exemptions,…