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BLACK v. UNITED STATES

Nos. 18926, 18927.

353 F.2d 885 (1965)

Fred B. BLACK, Jr., Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals District of Columbia Circuit.

Decided November 10, 1965.

Petition for Rehearing Denied January 17, 1966.

Attorney(s) appearing for the Case

Mr. Bert B. Rand, Washington, D. C., with whom Messrs. Hans A. Nathan, Warren E. Magee and Thomas G. Laughlin, Washington, D. C., were on the brief, for appellant.

Mr. K. William O'Connor, Atty., Dept. of Justice, with whom Asst. Atty. Gen. Louis F. Oberdorfer, Messrs. John P. Burke, Richard B. Buhrman and Joseph M. Howard, Attys., Dept. of Justice, were on the brief, for appellee. Messrs. David C. Acheson, U. S. Atty. at the time the record was filed, and Frank Q. Nebeker, Asst. U. S. Atty., also entered appearances for appellee.

Before WILBUR K. MILLER, Senior Circuit Judge, and DANAHER and McGOWAN, Circuit Judges.

Petition for Rehearing En Banc and for Rehearing before the Division Denied January 17, 1966.

McGOWAN, Circuit Judge.

These appeals are from convictions under two indictments charging appellant with violations of Section 7201 of the Internal Revenue Code of 1954. 26 U.S.C. § 7201. That statute imposes criminal sanctions upon "Any person who willfully attempts in any manner to evade or defeat" federal tax liability. One indictment related to the year 1956...

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