MEMORANDUM
POLLACK, District Judge.
SUMMARY
On January 27, a jury found Singleton guilty of two lesser included counts of wilful failure to file tax returns, 26 U.S.C. § 7203. At the same time, the jury announced that it was unable to agree on a verdict on four counts of tax evasion, 26 U.S.C. § 7201, among them the counts which included the lesser offenses of failure to file, and a mistrial...
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