Erne appeals from his conviction on four counts of violating 26 U.S.C. § 7215, a provision of the Internal Revenue Code. He contends that the district judge erroneously interpreted the statute and improperly refused to hold an evidentiary hearing on his claim of discriminatory prosecution. We affirm.
I
In January 1974, Erne became president of California Aero Topo (C.A.T.), a...
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