U.S. v. MICHAUD

No. 88-1440.

860 F.2d 495 (1988)

UNITED STATES of America, Appellee, v. Hubert MICHAUD, Defendant, Appellant.

United States Court of Appeals, First Circuit.

Decided October 31, 1988.


Attorney(s) appearing for the Case

Richard O. Lessard with whom Joseph J. Rodio, Rodio & Ursillo, Ltd., William A. Dimitri, Jr., Providence, R.I., Lorraine L. Hansen, and L.L. Hansen Legal Professional Association, Portsmouth, N.H., were on brief, for defendant, appellant.

Alan Hechtkopf, Tax Div., Dept. of Justice, with whom William S. Rose, Jr., Asst. Atty. Gen., Washington, D.C., Richard V. Wiebusch, U.S. Atty., Concord, N.H., Gary R. Allen and Robert E. Lindsay, Tax Div., Dept. of Justice, Washington, D.C., were on brief, for appellee.

Before BOWNES and BREYER, Circuit Judges, and ATKINS, Senior District Judge.


BREYER, Circuit Judge.

Hubert Michaud appeals his conviction for "willfully attempt[ing] ... to evade ... [income] tax" liability for the years 1980 and 1981. 26 U.S.C. § 7201 (1982). His appeal is based on governmental misconduct and insufficiency of the evidence. We affirm his conviction.

1. The facts, as the jury might have found them, include the following:

a) In December 1980 Michaud, a businessman, donated a campground that he owned to the...

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