Rehearing and Rehearing En Banc Denied April 30, 1985.
TATE, Circuit Judge:
The defendant Eugene Tafoya appeals his conviction on two counts of violating 26 U.S.C. § 7206(1) by filing materially false tax returns for the tax years 1980 and 1981. An indictment charged that Tafoya willfully and falsely understated his gross income on his 1980 and 1981 tax returns.
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