OPINION
RUSSELL E. SMITH, Chief Judge.
Defendant was convicted on three counts of failing to file federal income tax returns for the years 1969, 1970, and 1971, in violation of 26 U.S.C. § 7203.
On motion for a new trial, or in the alternative for judgment notwithstanding the verdict (treated as a motion for judgment of acquittal), the defendant contends that the evidence was insufficient.
Defendant is a certified public accountant who...
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