HILL, Circuit Judge.
Appellant, James G. Ryan, was tried and convicted before a jury, in the United States District Court for the District of Colorado, upon an information containing six counts, all brought under 26 U.S.C. § 7203. Each count charged a wilful failure to file the required employer's quarterly tax return. Counts I, III and V concerned employees income taxes withheld, and, Counts II, IV and VI concerned Federal Insurance Contributions Act
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