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UNITED STATES v. FOX

No. 1380, Docket 83-6055.

721 F.2d 32 (1983)

UNITED STATES of America and Mary Jane Sciascia, Revenue Agent, Petitioners-Appellees, v. Dr. Martin FOX, Respondent-Appellant.

United States Court of Appeals, Second Circuit.

Decided October 19, 1983.

Attorney(s) appearing for the Case

Richard E. Timbie, Washington, D.C. (Scott D. Michel, Caplin & Drysdale, Washington, D.C., Denise G. Shekerjian, Stillman, Friedman & Shaw, New York City, of counsel), for respondent-appellant.

Stephen A. Dvorkin, Asst. U.S. Atty., S.D.N.Y., New York City (John S. Martin, Jr., U.S. Atty., S.D.N.Y., Leona Sharpe, Thomas D. Warren, Asst. U.S. Attys., S.D.N.Y., New York City, of counsel), for petitioners-appellees.

Before OAKES and MESKILL, Circuit Judges, and HILL, District Judge.

MESKILL, Circuit Judge:

The federal tax structure is based on a system of self-reporting which relies on "the good faith and integrity of each potential taxpayer to disclose honestly all information relevant to tax liability." United States v. Bisceglia, 420 U.S. 141, 145, 95 S.Ct. 915, 918, 43 L.Ed.2d 88 (1975). We have recognized repeatedly that the Internal Revenue Service is "indispensable" to the administration of the revenue...

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