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United States v. Harris

United States Court of Appeals for the Seventh Circuit
942 F.2d 1125 (7th Cir. 1991)


Lynnette Harris and Leigh Ann Conley (defendants), who were twin sisters, each received over $500,000 over the course of several years from David Kritzik, a wealthy widower. Harris and Conley were mistresses of Kritzik. Kritzik wrote letters to Harris expressing the joy that he felt from giving these gifts to her. However, on Kritzik’s tax returns, he reported only nominal amounts as gifts, failing to report the vast majority of the funds that he provided to the sisters. Harris referred to her relationship with Kritzik as a job and picked up a check at Kritzik’s office on a regular schedule. The United States indicted the two sisters on charges of criminal tax evasion, charging that the sisters’ failure to pay taxes on the money received from Kritzik constituted knowing and willful evasion of tax liability. The two sisters were convicted, were fined in federal district court, and began serving prison sentences. The two sisters appealed.

Rule of Law


Holding and Reasoning (Eschbach, J.)

Concurrence (Flaum, J.)

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