NELSON, Circuit Judge:
Sorkis J. Webbe appeals his jury conviction on two counts of making and filing a false income tax return in violation of 26 U.S.C. § 7206(1). Webbe, along with several others, had earlier been acquitted of conspiracy to defraud a union pension fund (United States v. Linton, CR-80-24-ECR). Webbe argues that the government was barred by collateral estoppel from trying him on the tax charges, because of his earlier acquittal on the...
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