HENLEY, Senior Circuit Judge.
Steven Felak, Jr. was indicted by grand jury for three counts of criminal income tax evasion in violation of 26 U.S.C. § 7201 for the 1979, 1980 and 1981 tax years. The indictment charged that during the years in question, Felak violated § 7201 in one or more of the following particulars: by failing to file income tax returns, failing to pay taxes due and owing, concealing income, filing false withholding certificates, and concealing...
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