HILL, Circuit Judge.
Maurice Malcolm Dillon was convicted on both counts of an information charging him with willful failure to file income tax returns for the calendar years 1972 (Count I) and 1973 (Count II), in violation of 26 U.S.C. § 7203. Dillon was sentenced to six months' incarceration on Count I; the sentence on Count II was suspended, and appellant was placed on probation for a period of three years to commence following his incarceration.
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