UNITED STATES v. CLARDY

No. 78-2373.

612 F.2d 1139 (1980)

UNITED STATES of America, Plaintiff-Appellee, v. John D. CLARDY, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied February 19, 1980.


Attorney(s) appearing for the Case

Nancy L. Simpson, Asst. U. S. Atty., San Francisco, Cal., for plaintiff-appellee.

Jerome B. Falk, Jr., San Francisco, Cal., for defendant-appellant.

Before CHOY and ANDERSON, Circuit Judges, and WYATT, District Judge.


WYATT, District Judge:

John D. Clardy appeals from a judgment of conviction in the United States District Court for the Northern District of California on three counts of an indictment charging him with three separate violations of 26 U.S.C. § 7206(2). That section, in relevant part, makes it an offense if any person "[w]illfully aids or assists in, or procures, counsels, or advises the preparation or presentation under . . . the internal revenue laws, of a return...

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