HOLLAND et ux. v. UNITED STATES (348 U.S. 121)
U.S. Supreme Court · decided December 6, 1954 · Supreme Court Database (Spaeth)
- Citation
- 348 U.S. 121 · 75 S. Ct. 127
- Decided
- December 6, 1954
- Term
- October Term 1954
- Vote
- 8–0
- Majority author
- Justice Clark
- Issue area
- Criminal Procedure
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Mr. Justice Clark delivered the opinion of the Court. Petitioners, husband and wife, stand convicted under § 145 of the Internal Revenue Code 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 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. In recent years, however, tax-evasion convictions obtained under the net worth theory have come here with increasing frequency and left impressions beyond those of the previously unrelated petitions. We concluded that the method involved something more than the ordinary use of circumstantial evidence in the usual criminal case. Its bearing, therefore, on the safeguards traditionally provided in the administration of criminal justice called for a consideration of the entire theory. At our last Term a number of cases arising from the…
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