Page:Brief for the United States, Wong Sun v. United States, 371 U.S. 471 (1963).djvu/59

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where the independent evidence was admittedly insufficient to prove the whole case in itself but was found to be enough to indicate that the various admissions were reliable. Thus, in Smith v. United States, 348 U.S. 147, quoted above, an admission that the taxpayer had small net worth at the commencement of an income-tax prosecution period was held sufficiently corroborated by such nondispositive but supporting facts as recitals of low income in tax returns prior to the net worth date. The recitals in earlier returns might well have been falsified but they nevertheless were consistent with the statement of a low net worth. Similarly, the employment of the taxpayer at low pay prior to the net worth date was corroborative of low net worth, although the low pay would not preclude substantial assets held from a long time before, which might have negated a low net worth. Corroboration was also found in the taxpayer's conduct during the prosecution period, in the form of large expenditures and a new racing-news business in which he kept no records (id., 157–159).

In Opper v. United States, supra, 348 U.S. 84, the accused's admission that he paid the money to a government official (although in the admission it was asserted that this was only a loan) was held corroborated by a check drawn by the defendant, together with the records of a concurrent long-distance call to Opper's home from the employee's home, and an airline ticket in the employee's name to Opper's city. There, again, any or all of the cor-