Siravo v. United States

377 F.2d 469 (1967)

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Siravo v. United States

United States Court of Appeals for the First Circuit
377 F.2d 469 (1967)

Facts

William Siravo (defendant) filed tax returns for the years 1958–1960 that reflected wage income from Siravo Motor Sales. Although Siravo also operated a jewelry-assembling company, his returns did not report any profit or loss from business or attach a separate profit-or-loss schedule. Siravo signed the returns, declaring under penalties of perjury that the returns were true, correct, and complete. Siravo was charged with failing to disclose gross receipts from a business activity in violation of the tax-perjury statute and failing to file a tax return for the year 1961. The evidence showed that Siravo’s jewelry-assembling business had gross income and would have required laborers, but no evidence was introduced as to the cost of materials or labor. Siravo was convicted and argued on appeal that 26 U.S.C. § 7206(1) is a perjury statute, perjury requires a false statement of fact, and the failure to attach the profit-or-loss schedule was not a false statement. The government (plaintiff) contended that § 7206(1) can be violated by the knowing and willful omission of facts.

Rule of Law

Issue

Holding and Reasoning (Coffin, J.)

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