HENLEY, Senior Circuit Judge:
James Howard appeals his conviction on two counts of intentionally signing false tax returns for the year 1982 in violation of 26 U.S.C. § 7206(1). Howard was sentenced by the district court to eighteen months in prison on the first count, to be followed by a period of five years of probation on the second count. In addition, the court imposed a fine of $15,000.00.
In June of 1982, Howard entered into a written agreement...
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