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U.S. v. ROGERS

No. 87-5678.

853 F.2d 249 (1988)

UNITED STATES of America, Plaintiff-Appellee, v. Samuel E. ROGERS, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided August 2, 1988.

Attorney(s) appearing for the Case

Patricia Ruth Moss, Deputy Federal Public Defender (William E. Martin, Federal Public Defender, Raleigh, N.C., on brief), for defendant-appellant.

Alan Hechtkopf (William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, Robert E. Lindsay, Tax Div., Dept. of Justice, Washington, D.C., Margaret P. Currin, U.S. Atty., Raleigh, N.C., on brief), for plaintiff-appellee.

Before WIDENER, SPROUSE, and ERVIN, Circuit Judges.

ERVIN, Circuit Judge:

Samuel Rogers was convicted on twenty-four counts of preparing false tax returns in violation of 26 U.S.C. § 7206(2).1 He raises numerous issues on appeal. We affirm.

I.

Rogers was in the business of preparing income tax returns. These charges arose from ten 1979 returns and fourteen 1980 returns. Fifteen witnesses testified that Rogers prepared false tax returns for them. Several testified...

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