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INGRAM V. UNITED STATES, 360 U. S. 672 (1959)

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U.S. Supreme Court

Ingram v. United States, 360 U.S. 672 (1959)

Ingram v. United States

No. 457

Argued April 30, 1959

Decided June 29, 1959

360 U.S. 672

Syllabus

The four petitioners and certain others were convicted of violating 18 U.S.C. § 371 by conspiring to evade and defeat the payment of the federal taxes imposed on lottery operations. All of them had participated in the conduct of, and in an attempt to conceal, lottery operations which were violations of state law. Two of the petitioners were proprietors of the enterprise, and were liable for the federal wagering taxes, and they failed to pay them. The other two were mere employees who were not liable for the payment of such taxes, and there was nothing in the record to show that they knew that the taxes had not been paid.

Held:

1. The evidence was sufficient to support a conclusion that the two petitioners who were proprietors of the business were parties to an agreement to attempt to defeat or evade payment of the federal wagering taxes imposed upon them, and their convictions are sustained. Pp. 360 U. S. 676-677.

2. Since there is nothing in the record to show that the two petitioners who were mere employees knew of the proprietors' liability for these taxes, the record is insufficient to show that they were parties to a conspiracy to evade and defeat the payment of such taxes, and their convictions cannot stand. Pp. 360 U. S. 677-681.

259 U.S. 886 affirmed in part and reversed in part.


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