United States v. Calderon (348 U.S. 160)
U.S. Supreme Court · decided December 6, 1954 · Supreme Court Database (Spaeth)
- Citation
- 348 U.S. 160 · 75 S. Ct. 186
- Decided
- December 6, 1954
- Term
- October Term 1954
- Vote
- 7–1
- Majority author
- Justice Clark
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Mr. Justice Clark delivered the opinion of the Court. The issue in this case is similar to the question presented in Smith v. United States, ante, p. 147, on the corroboration of respondent’s extrajudicial statements concerning his “opening net worth.” The admissibility of these statements is not questioned. Respondent, an operator of a legitimate coin-machine business, was tried and convicted on four counts charging him with willful attempts to evade and defeat his own and his wife’s income taxes for the years 1946 through 1949. The Government’s case rested primarily on a net worth, computation, which showed net worth increases and nondeductible expenditures of $62,993.47 for the prosecution period; during these same four years respondent declared only $16,775.14 income. It was stipulated that the computation was correct except as to the items "cash on hand” and “cash in bank.” Respondent’s bank balances were proved by introducing the bank records, and, with some minor adjustments, the Government’s net worth computation was amply verified in this respect. As to “cash on hand,” particularly the amount credited to the taxpayer as of the beginning of the prosecution period, respondent contends that the only evidence tending to substantiate the Government’s figures is the uncorroborated admissions of the accused. He argues that lacking independent evidence of the corpus delicti,…
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