United States v. Denniston

CHASE, Circuit Judge.

The appellant was, on December 28, 1934, indicted by a grand jury sitting in the Southern District of New York for willful and fraudulent evasion of income taxes for the calendar years 1931, 1932, and 1933; there being a count in the indictment for each year. On January 7, 1935, the defendant pleaded not guilty in the District Court for the Southern District of New, York and was released on bail. He had made, on October 18, 1934, an offer in compromise of any civil and criminal liability, none of which was admitted, and tendered the government his check but his offer was…