OPINION
TYLER, District Judge.
The defendant, Bak G. Chin, was indicted on April 10, 1962 on two counts of willful evasion of income tax for the years 1955 and 1956. On May 18, 1962, defendant appeared and pleaded not guilty. The defendant promptly moved for a bill of particulars. At a hearing, the government stated that it would proceed on a net worth expenditure theory of proof, and on June 26, 1962, Judge Noonan issued an order granting the government...
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