BARNES, Circuit Judge.
Appellant, a physician and surgeon duly licensed for many years to practice his profession in California, in 1953 entered a plea of nolo contendere to two counts of violating Title 26 U.S.C. § 145(b) (I.R.C. 1939). The indictment had charged him in three counts of wilfully and knowingly attempting to defeat and evade his income tax in the years 1946, 1947 and 1948 by filing false and fraudulent returns. Appellant entered a not guilty plea...
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