Friedberg v. United States

How later courts describe this case

• stating that the Commissioner's method of reconstructing income is reasonable if it is "rationally based"
• determining that "evidence of a consistent pattern of underreporting large amounts of income" supports "an inference of willfulness"
• "The bank deposits method of proof is also a circumstantial way of establishing unreported income."
• "The bank deposits method of proof is * * * a circumstantial way of establishing unreported income."
• "To protect the revenue from those who do not render true accounts, the Government must be free to use all legal evidence available to it in determining whether the story told by the taxpayer's books accurately reflects his financial history" (internal quotation marks omitted)
• net worth method of reconstructing income valid