Fred B. Black, Jr. v. United States

McGOWAN, Circuit Judge.

These appeals are from convictions under two indictments charging appellant with violations of Section 7201 of the Internal Revenue Code of 1954. 26 U.S.C. § 7201. That statute imposes criminal sanctions upon “Any person who willfully attempts in any manner to evade or defeat” federal tax liability. One indictment related to the year 1956; and the other to 1957, 1958, and 1959. The 1959 count was dismissed by the Government at the outset of the trial, but the latter *887eventuated in jury findings of guilt as to the other years. Concurrent sentences of confinement and fine…