COFFRIN, District Judge:
This is an appeal from a conviction entered after a jury trial in the United States District Court for the Eastern District of New York, Bramwell, J., for two counts of violating 26 U.S.C. § 7206(2) by unlawfully and willfully causing the preparation and presentation of a United States Information Return (Internal Revenue Service ("IRS") Form 1099) which was false and fraudulent as to material matters.
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