BREYER, Circuit Judge.
The government has charged Norman Irvine with willfully failing to file federal income tax returns from 1975 to 1979, in violation of 26 U.S.C. § 7203. The district court found that, at a February 1981 meeting, an IRS officer failed to state that he was conducting a criminal investigation when warning Irvine and his wife of their constitutional rights. This omission violated an IRS regulation on the subject, IRM 9384.2(2)(a)(b), NAR Pub...
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