TRASK, Circuit Judge:
Defendant-Appellant Crowhurst appeals from his conviction of two counts of willfully filing false tax returns in violation of 26 U.S.C. § 7206(1) and three counts of willful failure to file tax returns in violation of 26 U.S.C. § 7203. These violations occurred in the years 1970-74.
During his trial, appellant proceeded pro se, with the limited assistance of appointed "standby" counsel. Following an earlier trial on the same...
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