Holland v. United States
- Decided
- January 31, 1955
- Docket
- 37
- Status
- Published
- Jurisdiction
- Federal
Cited 3,238 timesDisapproved (not yet verified)Possible negative treatment: disapproved (not yet verified) · Homer L. Woxberg, Sr., and Wayne Franklin Dykes v. United States
What later courts said
- holding that the government always retains the ultimate burden of proving every element of a tax offense beyond a reasonable doubt — United States v. Salvatore James Pisello (1989)
- holding that a pattern of consistently and substantially underreporting income may justify an inference of fraud — Shah v. Commissioner (1999)
- holding that a pattern of consistently and substantially -8- [ ] underreporting income may justify an inference of fraud — Tamatha D. Byrum & Micheal B. Byrum v. Commissioner (2018)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
[*124] Mr. Justice Clark delivered the opinion of the Court.
Petitioners, husband and wife, stand convicted under § 145 of the Internal Revenue Code [1] of an attempt to evade and defeat their income taxes for the year 1948. The prosecution was based on the net worth method of proof, also in issue in three companion cases [2] and a number of other decisions here from the Courts of Appeals of nine circuits. During the past two decades this Court has been asked to review an increasing number of criminal cases in which proof of tax evasion rested on this theory. We have denied certiorari because the cases involved only questions of evidence and, in isolation, presented no important questions of law. In 1943 the Court did have occasion to pass upon an application of the net worth theory where the taxpayer had no records.
United States v. Johnson, 319 U. S. 503.
Statutes cited
Cite this
Holland v. United States, 348 U.S. 121 (1955)Read the full opinion
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