United States v. Joseph Conforte and Sally Conforte

KENNEDY, Circuit Judge:

This is an appeal from a judgment of conviction in a tax evasion case. The appellants, Joseph and Sally Conforte, are the operators of an establishment called “Mustang Ranch,” described in the record as a legalized house of prostitution located in Nevada. The Confortes were convicted on four separate violations of 26 U.S.C. § 7201 for willful acts taken to evade or defeat federal employment taxes for the last quarter of 1974 and the first three quarters of 1975. The Government’s case was that the appellants willfully failed to file employment tax returns, to withhold…