In what circumstances have courts found there to be conspiracy between two men who sold counterfeit bills to a third party?

In United States v. Peoni (2d Cir. 1938) 100 F.2d 401, one man sold counterfeit bills to a second who, in turn, sold them to a third, all knowing them to be counterfeit and the first man knowing that his buyer probably would sell them so as to put them into circulation. The court held that this was not enough to support a finding of conspiracy by the original seller. Other cases could be cited for the same basic proposition. ⁴

Tested by the rules above set forth, we turn to examine the evidence against Samarjian on the conspiracy count.