United States v. Sidney A. Brodson

SCHNACKENBERG, Circuit Judge.

Plaintiff appeals from an order entered by the district court which inter alia sustained defendant’s motion to dismiss an indictment charging defendant with willful attempted evasion of his income tax for each of the years 1948 to 1950 inclusive, in violation of section 145(b) of the Internal Revenue Code of 1939.1 Pri- or to the return of the indictment, a *108jeopardy assessment was made and tax liens were filed against the defendant in the amount of $342,120.37 for income taxes and additions thereto for fraud, plus interest, for the years 1945 to 1950, inclusive.

In…