OPINION OF THE COURT
GIBBONS, Circuit Judge.
James W. Busk is before us on separate appeals from judgments of sentence entered following two convictions. One conviction, No. 82-1101, is on four counts of an eight count indictment for willfully attempting to evade payment of the excise tax on wages and the special occupational tax on wagering activity. 26 U.S.C. § 7201 (1976). The other, No. 82-1144, is for conducting an illegal gambling enterprise....
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