HARLINGTON WOOD, Jr., Circuit Judge.
In early 1984, a jury found Richard A. Ginsburg guilty of 19 counts of mail fraud under 18 U.S.C. § 1341 and one count of racketeering under 18 U.S.C. § 1962(c), all of which stemmed from Ginsburg's payments to fix cases while practicing before the Cook County Board of Tax Appeals ("the Board"). Following the Supreme Court's decision in McNally v. United States,
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