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Spies v. United States

317 U.S. 492 (1943)

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Spies v. United States

United States Supreme Court

317 U.S. 492 (1943)

Facts

Spies (defendant) was convicted of felony tax evasion under Internal Revenue Code (I.R.C.) § 145(b) (now codified at 26 U.S.C. § 7201). Spies admitted he earned enough income to trigger the statutory requirement to file a tax return and pay income taxes. He admitted that he did neither. Spies claimed that he lacked a willfulness to evade taxes because he had a physical illness and psychological disturbance at the time his return was due. Evidence introduced at trial showed that Spies insisted some income be paid in cash, that he failed to keep full and correct financial records, and that he deposited money received in banks under the names of family members. Spies requested a jury instruction that more than a mere willful failure to make a return or pay an income tax was required for a conviction of felony tax evasion. Instead, the court instructed the jury that an attempt to evade paying an income tax did not require an affirmative act for conviction and that inactivity or omission may provide a basis for felony tax evasion. Spies was convicted for felony tax evasion. The appellate court affirmed. Spies appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Jackson, J.)

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