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UNITED STATES v. PALERMO

No. 12532.

259 F.2d 872 (1958)

UNITED STATES of America v. Frank PALERMO, also known as Frank "Blinky" Palermo, Appellant.

United States Court of Appeals Third Circuit.

Decided October 2, 1958.

Rehearing Denied October 23, 1958.

Attorney(s) appearing for the Case

Jacob Kossman, Philadelphia, Pa., for appellant.

Joseph L. McGlynn, Asst. U. S. Atty., Philadelphia, Pa. (Harold K. Wood, U. S. Atty., Philadelphia, Pa., on the brief), for appellee.

Before KALODNER and HASTIE, Circuit Judges, and LAYTON, District Judge.

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 19391 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...

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