United States v. Perry Russell Tunnell

AINSWORTH, Circuit Judge.

Perry Russell Tunnell was convicted on each of three counts for willfully attempting to evade federal income tax during the years 1965, 1966, and 1967, in violation of 26 U.S.C. § 7201 (1970). 1 The central issue on appeal concerns the sufficiency of the Government’s evidence based on the net worth method. We affirm.

I

One of the essential elements which the Government had to prove was that taxpayer owed tax on at least some unreported income for each of the three years named in the indictment. Because taxpayer’s records were inadequate, the Government utilized the…