GOLDBERG, Circuit Judge:
Convicted on three counts of felony tax evasion under 26 U.S.C. § 7201, Doyle contends that the district court erred in refusing to instruct the jury on the lesser-included misdemeanor offense of failing to file a tax return, 26 U.S.C. § 7203. Finding merit in Doyle's argument, we vacate the convictions and remand for a new trial.
BACKGROUND
The facts germane to this appeal are largely...
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