O'KELLEY, District Judge:
In this appeal, Paul M. Phillips raises two challenges to his November 3, 1986 conviction for the offenses of failing to file income tax returns for the years 1979 and 1980 in violation of 26 U.S.C. § 7203. In his first challenge, Phillips contends that the district court erred in failing to grant his motion for judgment of acquittal on count one of the indictment because the six-year statute of limitations for failure to file a return...
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