HOLLOWAY, Chief Judge.
The defendant Jack D. Greenwood was charged in a two-count information with willfully failing to file federal income tax returns for the years 1974 and 1975, in violation of 26 U.S.C. § 7203 (1982). I R. 12-14. Plea negotiations ensued, and the defendant pled guilty to the second count relating to his 1974 tax return and the Government moved for dismissal of the first count involving his 1975 tax return.
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