PERRY, Senior District Judge.
George Roman Dreske, defendant below, appeals his conviction and sentence for failing to deposit withheld Federal Insurance Contributions Act [hereinafter "F.I.C.A."] taxes in a separate bank account in violation of 26 U.S.C. § 7215, an Internal Revenue Code provision which penalizes an employer's unlawful failure to comply with another Internal Revenue Code provision, 26 U.S.C. § 7512,
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