LAY, Chief Judge.
Alan K. Stuart was convicted in a jury trial on three counts of willful failure to file income tax returns for the years 1974, 1975 and 1976 in violation of 26 U.S.C. § 7203 (1976). He was fined $5,000 and was sentenced to one year imprisonment on the first count. On the second count he received a suspended sentence and one year of probation consecutive to incarceration, and on count three a suspended sentence and one year of probation to run...
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