Kritzik, was a wealthy widower partial to the company of young women. Two of these women were Conley (D) and Harris (D), twin sisters. Directly or indirectly, Kirtzik gave each more than $500,000 over the course of several years. Either, Kritzik or the women had to pay taxes, either gift or income on the money. The United States alleges that the obligation was on the women. In separate criminal trials, both women were convicted of willfully evading their income tax obligation. Both appealed. They were required to make a return only if the money received was income rather than a gift.

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