BREITENSTEIN, Circuit Judge.
Petersen appeals from his conviction on a two-count indictment charging income tax evasion by the filing of false returns covering the years 1951 and 1952. Trial was to a jury. The sentence was two years on each count, to run concurrently, and a $5,000 fine on each count.
By use of the net worth method of proof the government established substantial tax deficiencies in each of the
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