Eleventh Circuit: USA v. Harvey Zitron

Tax, FrCrimP

No error in joining tax crimes with fraud crimes in the indictment, as prejudice was speculative.

Comment elicited on cross about hypothetical silence of deft didn't violate 5A, shift burdens.

Where deft has in the past opened credit accounts for family, doing so with unlawful intent suffices for statutory bar on knowingly opening the account with unlawful authority.

No plain error in court's determining amount of fraud based on scope of fraud versus funds deposited by deft.

Leadership enhancement upheld.

http://media.ca11.uscourts.gov/opinions/pub/files/201410009.pdf