Will Parks Clay, Walter Jolly, Andrew B. Turk and Andrew Morris v. United States

The appellants were convicted of willfully attempting to evade the wagering occupational tax imposed by § 3290 of the Internal Revenue Code 1 persons engaged in the business of accepting wagers, in violation of § 2707(c) of the Code, as made applicable by § 3294(c) thereof. It was stipulated that the tax was not paid, and, although appellants contend otherwise, the evidence 2 was sufficient to warrant a finding by the jury that appellants were liable for the payment of the tax and willfully failed to pay it. As grounds for reversal of this conviction, appellants contend: (1) that the…