OPINION
SNEED, Circuit Judge:
Appellant was charged in a two-count indictment for willfully causing P. B. Industries, Inc., a corporation of which he was president, to fail to truthfully account for and pay over employees' federal income withholding taxes on wages and social security (FICA) taxes for the first two quarters of 1973 in violation of 26 U.S.C. § 7202. That section is as follows:
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