The following excerpt is from United States v. Cole, 90 F. Supp. 147 (S.D. Cal. 1950):
"We are asked to hold that there is no evidence of willful intent to evade the tax, it being claimed that the showing does not measure up to the standards set in Spies v. United States, 1943, 317 U.S. 492, 63 S.Ct. 364, 87 L.Ed. 418.
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