United States v. O'Connor

FRIENDLY, Circuit Judge.

This appeal concerns the civil side of the long-standing tax controversy between the United States and Raymond A. O’Connor of Niagara Falls. O’Connor was convicted in 1954 and again in 1957 of wilfully attempting to evade payment of his income taxes for 1946-1949; both convictions were reversed by this Court on grounds not going to the merits of the Government’s claim, 1956, 237 F.2d 466; 1959, 273 F.2d 358.

On September 12, 1951, the Commissioner made jeopardy assessments against Raymond O'Connor and his wife Bertha for deficiencies in income taxes, fraud penalties and…