United States v. Thomas G. Heyward

BULLOCK, District Judge:

Thomas G. Heyward was convicted in March 1982, in a trial by jury, of two counts of income tax evasion in violation of 26 U.S.C. § 7201. The government’s case rested on the net worth theory of proof, which requires either a negativing of all the possible nontaxable sources of the defendant’s net worth increases over the years in question, or the establishment of a “likely source” of income. United States v. Massei, 355 U.S. 595, 78 S.Ct. 495, 2 L.Ed.2d 517 (1958). The instant case proceeded along the latter route, with the government convincing the jury that Hey-ward’s…