Smith v. United States (348 U.S. 147)

U.S. Supreme Court · decided December 6, 1954 · Supreme Court Database (Spaeth)

Citation
348 U.S. 147 · 75 S. Ct. 194
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. This is the third of the net worth cases and the first dealing with the Government’s use of extrajudicial statements made by the accused. Petitioner and his wife were jointly tried on five counts charging them with willful attempts to evade and defeat their income taxes for the years 1946 through 1950. A motion for acquittal was granted as to the wife on all five counts, and as to petitioner on the fifth count (for the year 1950). The jury found petitioner guilty on the first four counts, and the conviction was affirmed by the Court of Appeals. 210 F. 2d 496. We granted certiorari in order to pass on the issues raised by the prosecution’s use of defendant’s extrajudicial statements. 347 U. S. 1010. The Government’s theory was that the increases in the net worth of petitioner and his wife exceeded their reported income for each of the prosecution years, and that these increments represented taxable income. The evidence tended to show that petitioner and his wife were persons of moderate means prior to 1945, and that toward the end of that year petitioner acquired a racing-news service. In the four succeeding years, the prosecution years here in issue, petitioner and his wife acquired a large amount of visible wealth in the form of bank accounts, real estate, securities, and other assets. The evidence, taken as a whole,…

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