This section contains the nature of the case and procedural background.

Fowler (D) decided that in 1953 he no longer wanted to pay income taxes. He was finally brought to trial for the failure to pay for the years 1971-1975. He cooperated with investigators but only provided them with partial records of his business affairs. The government used the bank deposit method of proving his taxes and D, who represented himself pro se was convicted. D appealed with the help of an attorney.

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