Sansone v. United States
United States Supreme Court
380 U.S. 343, 85 S. Ct. 1004, 131 L. Ed. 2d 882 (1965)
- Written by Steven Pacht, JD
Facts
Michael Sansone (defendant) was charged with willfully attempting to evade his 1957 taxes in violation of Internal Revenue Code (code) § 7201 due to his failure to report a land sale on his tax return. Sansone conceded that he should have reported the sale, but Sansone argued that he did not willfully understate his taxes because he believed that the cost of extensive repairs on his remaining property would swallow his 1957 profits. In response, the United States introduced Sansone’s signed statement claiming that he did not report the 1957 sale because he did not have enough money to pay the tax but that he intended to pay in the future when he had more money. Sansone asked the district court to instruct the jury that it could acquit him of violating § 7201, which was a felony, but convict him of lesser included misdemeanor offenses of violating either or both of code § 7203 (failing to pay tax when due) and § 7207 (filing a false or fraudulent return). The district court denied Sansone’s request. The jury convicted Sansone. The court of appeals affirmed. Sansone appealed.
Rule of Law
Issue
Holding and Reasoning (Goldberg, J.)
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