Ellen Armstrong and David, J. Armstrong v. United States

JERTBERG, Circuit Judge:

Following trial to a jury, the appellants Ellen Armstrong and David J. Armstrong, husband and wife, were convicted on each count of a four count indictment. The indictment charged that appellants did willfully and knowingly attempt to evade and defeat a large part of the income tax due and owing by them to the United States of America for the calendar' years 1956 through 1959, respectively, in violation of Title 26 U.S.C. § 7201, which in pertinent part provides:

“Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the…