In United States v. Holland, 348 U.S. 121 (1954), the federal government prosecuted a husband and wife for willful evasion of income tax. The government based its case upon the "net worth" method of proof. The Court had previously approved use of this tactic in cases against gangsters and known criminals, thereby allowing the government to establish "taxable income from undisclosed sources when all other efforts failed." Irene Merker Rosenberg & Yale L. Rosenberg, "Perhaps What Ye Say is Based only on Conjecture" - - Circumstantial Evidence, Then and Now, 31 Hous. L. Rev. 1371, 1392-93 (1995). Use of this method at trial involved the introduction of circumstantial evidence. On appeal, the husband and wife averred, inter alia, the federal district court erred when it did not give the "reasonable hypothesis" instruction when the jury was charged. The Court, however, did not agree: "The husband and wife press upon us, finally, the contention that the instructions of the trial court were so erroneous and misleading as to constitute grounds for reversal. We have carefully reviewed the instructions and cannot agree. But some require comment. The petitioners assail the refusal of the trial judge to instruct that where the Government's evidence is circumstantial it must be such as to exclude every reasonable hypothesis other than that of guilt. There is some support for this type of instruction in the lower court decisions ... but the better rule is that where the jury is properly instructed on the standards for reasonable doubt, such an additional instruction on circumstantial evidence is confusing and incorrect.... Circumstantial evidence in this respect is intrinsically no different from testimonial evidence. Admittedly, circumstantial evidence may in some cases point to a wholly incorrect result. Yet this is equally true of testimonial evidence. In both instances, a jury is asked to weigh the chances that the evidence correctly points to guilt against the possibility of inaccuracy or ambiguous inference. In both, the jury must use its experience with people and events in weighing the probabilities. If the jury is convinced beyond a reasonable doubt, we can require no more." Id. 348 U.S. at 139-40, 75 S. Ct. at 137-38.