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UNITED STATES v. VOORHIES

No. 80-1725.

658 F.2d 710 (1981)

UNITED STATES of America, Plaintiff-Appellee, v. Victor S. VOORHIES, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided October 8, 1981.

Attorney(s) appearing for the Case

Harvey D. Tack, Hochman, Salkin & DeRoy, Beverly Hills, Cal., for defendant-appellant.

Debra Wright, Washington, D. C., argued, for plaintiff-appellee; Michael L. Paup, Chief App. Sec., Washington, D. C., on brief.

Before FARRIS and NELSON, Circuit Judges, and CARROLL, District Judge.

FARRIS, Circuit Judge:

Victor Voorhies appeals his convictions for two counts of willful evasion of the payment of income taxes for calendar years 1970 and 1972. See 26 U.S.C. § 7201 (1976). He contends that (1) a conviction for evasion of the payment of taxes cannot be based on a determination and assessment of tax liability made final only after the period of criminality alleged in the indictment; (2) even if a conviction can be so based, tax liability...

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