ELY, Circuit Judge:
Marabelles appeals from his judgments of conviction under 26 U.S.C. § 7201 (1976) (two counts of attempted tax evasion for the years 1977 and 1978) and 26 U.S.C. § 7206(1) (1976) (one count of willfully filing a false tax return for the year 1977).
FACTUAL BACKGROUND
During the years...
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