United States v. Ted A. Neff

A jury found Ted A. Neff guilty of evading his federal income taxes for the years 1983, 1984, 1985, and 1986 under 26 U.S.C. § 7201. Although Neff never claimed to have filed federal income tax returns for these years (the Returns), at trial he claimed that the government could not prove that he did not file. The district court sentenced Neff to two years imprisonment, fined him $700,000, and ordered him to pay $81,816 in back-taxes plus interest and penalties as restitution. Two points merit discussion.

A. Public RecoRds Act

Before trial, the district court rejected Neffs contention that the…