Legal Opinion

United States v. Frank Palermo, Also Known as Frank 'Blinky' Palermo

Court of Appeals for the Third Circuit

Decided October 23, 1958No. 12532PublishedCited by 43 opinions

1Opinion of the Court

KALODNER, Circuit Judge.

What is the proper standard to be applied in determining “willful” failure to pay income taxes “at the time or times required by law” under Section 145(a) of the Internal Revenue Code of 1939 1 and Section 7203 of the Internal Revenue Code of 1954 ? 2

That is the primary issue presented by this appeal from the District Court’s judgment of conviction entered on its verdict of guilty (the trial was to the District Court) following its denial of defendant’s motion for a judgment of acquittal or for a new trial. 3

The issue is one of first impression in an appellate court.…

2Cases cited11 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Spies v. United StatesSupreme Court of the United States · 1943
  3. Bollenbach v. United StatesSupreme Court of the United States · 1946
  4. United States v. MurdockSupreme Court of the United States · 1934
  5. Arthur King Wilson v. United StatesCourt of Appeals for the Ninth Circuit · 1958

6 more not listed; retrieve them via the Exa API.

3Cited by43 opinions

  1. United States v. John Paul MalinowskiCourt of Appeals for the Third Circuit · 1973
  2. United States v. Richard E. HawkCourt of Appeals for the Ninth Circuit · 1974
  3. United States v. Edward M. OstendorffCourt of Appeals for the Fourth Circuit · 1967
  4. Bryan v. FawkesSupreme Court of The Virgin Islands · 2014
  5. United States v. Salvatore VitielloCourt of Appeals for the Third Circuit · 1966

38 more not listed; retrieve them via the Exa API.

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