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U.S. v. MAL

No. 90-50233.

942 F.2d 682 (1991)

UNITED STATES of America, Plaintiff-Appellee, v. Robert Singh MAL, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided August 21, 1991.

Attorney(s) appearing for the Case

Patrick Sampair, MacPherson & McCarville, Phoenix, Ariz., for defendant-appellant.

Gregory A. Vega, Asst. U.S. Atty., San Diego, Cal., for plaintiff-appellee.

Before PREGERSON, HALL and BRUNETTI, Circuit Judges.

CYNTHIA HOLCOMB HALL, Circuit Judge:

Robert Singh Mal appeals his conviction of four counts of tax evasion in violation of 26 U.S.C. § 7201. He alleges that the district court failed properly to instruct the jury on the "affirmative act" requirement of § 7201. Mal's additional allegations of error are based on his contention that § 7201 proscribes two separate and distinct offenses: the evasion of the assessment...

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