CUDAHY, Circuit Judge.
Johnny Motley prepared income tax returns on a contingency fee basis. The greater the refund, the greater his fee. In an effort to increase his income, Motley fabricated tax deductions to garner a greater refund for his clients and thus larger fees for himself. His clients signed the returns, claiming they were unaware of Motley's illegal technique. Motley never signed the returns, but he did mail a number of them himself. The remainder were...
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