Submitted Under Third Circuit Rule 12(6) February 8, 1985.
OPINION OF THE COURT
SLOVITER, Circuit Judge.
Appellant, John H. Isenhower, was convicted after a jury trial of failing to file income tax returns for the calendar years 1980 and 1981 in violation of 26 U.S.C. § 7203. The evidence at trial showed that Isenhower received gross income during calendar year 1980 of $30,321.67 and during calendar year 1981 of $14,136.87, and
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