YOUNG, District Judge:
Defendant has been indicted on twenty-eight counts of knowingly and willfully attempting to evade and defeat income taxes due to the United States of America, by preparing tax returns for various taxpayers for the years 1958, 1959, and 1960, obtaining from the taxpayers money to pay the taxes, and then keeping the money and not filing the returns.
Defendant has filed a motion to dismiss the indictment upon three grounds:
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