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U.S. v. WILLIAMS

No. 87-5290.

837 F.2d 1009 (1988)

UNITED STATES of America, Plaintiff-Appellee, v. James L. WILLIAMS, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

February 17, 1988.

Attorney(s) appearing for the Case

Michael J. Rosen, Miami, Fla., for defendant-appellant.

Leon B. Kellner, U.S. Atty., Miami, Fla., Michael Paup, Chief, Appellate Section, Tax Div., U.S. Dept. of Justice, Michael C. Durney, Tax Div., Dept. of Justice, Robert E. Lindsay, Gail Brodfuehrer, Washington, D.C., for plaintiff-appellee.

Before RONEY, Chief Judge, KRAVITCH, Circuit Judge, and HENDERSON, Senior Circuit Judge.

KRAVITCH, Circuit Judge:

I. BACKGROUND

James Williams was convicted of income tax evasion in violation of 26 U.S.C. § 7201 and of signing a false tax return in violation of 26 U.S.C. § 7206(1). At trial, the government proceeded against Williams under what is commonly referred to as the "net worth" method of proof. In a net worth case, the government attempts to prove tax evasion through circumstantial evidence, by showing an increase in the defendant...

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