In Holland v.U.S.(1954), the U.S.Supreme Court upheld an income tax evasion conviction on the basis of circumstantial evidence in the form of

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The net worth method is a circumstantial evidence method where the government establishes a taxpayer's likely income by subtracting the taxpayer's likely nondeductible expenses and beginning net worth from ending net worth. This method was used in the Holland v. U.S. case to establish the defendant's income and subsequent tax evasion.

In Holland V