JOHNSON, Circuit Judge:
This case arises on appeal from a jury verdict finding John Rigdon guilty of two counts of failure to file federal cash transaction reports under 31 U.S.C.A. § 5313 and two counts of intentionally concealing material facts from the I.R.S. under 18 U.S.C.A. § 1001. We affirm in part and reverse in part.
I. FACTS
In 1987, Rigdon was involved in the nascent operations of an off-shore bank
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