PER CURIAM:
This is an appeal from a judgment of conviction of the United States District Court for the Southern District of New York, Cannella, J., entered after a jury trial. John and Michele DiPetto were found guilty of four counts of willfully and knowingly attempting to evade income taxes in violation of 26 U.S.C. § 7201. On appeal the DiPettos contend the government failed to prove the elements of evasion of the assessment of income tax as it was...
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