Ingram v. United States

Summary

The Court held that the evidence supported the conspiracy convictions of the lottery operators who were liable for the federal wagering taxes and had concealed the business and its income, but did not support the convictions of two clerical employees who were not shown to know of that tax liability. The Court required proof that each alleged conspirator knew the facts establishing the federal tax obligation and possessed the criminal intent necessary for willful tax evasion. Justice Harlan, joined by Justices Douglas and Brennan, would have reversed all convictions because the record lacked direct evidence that any petitioner knew a tax was imposed.