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UNITED STATES v. BARSHOV

No. 83-5158.

733 F.2d 842 (1984)

UNITED STATES of America, Plaintiff-Appellee, v. Emanuel BARSHOV and James E. Ross, Defendants-Appellants.

United States Court of Appeals, Eleventh Circuit.

Rehearing Denied July 9 and July 10, 1984.

Attorney(s) appearing for the Case

Michael Tarre, Coral Gables, Fla., for Barshov.

Culverhouse, Botts, Mills & Cone, Hugh F. Culverhouse, Jr., Nathan D. Clark, Miami, Fla., for Ross.

Glenn L. Archer, Michael L. Paup, Chief Appellate Sec., Deborah Dawson, Robert E. Lindsay, Tax Div., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before GODBOLD, Chief Judge, TJOFLAT and HENDERSON, Circuit Judges.

ALBERT J. HENDERSON, Circuit Judge:

Emanuel Barshov and James E. Ross were convicted in the United States District Court for the Southern District of Florida on one count of conspiracy and twenty-three substantive counts for violations of the tax laws of the United States.1

PAN Properties, Ltd. ("PAN") and NAP Properties, Ltd. ("NAP") were limited partnerships formed in 1973 under the...

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