OPINION
NIEMEYER, Circuit Judge:
Richard M. Hirschfeld, a lawyer, was convicted of conspiracy to defraud the IRS in violation of 18 U.S.C. § 371 (Count I of the indictment against him), conspiracy to defraud the SEC in violation of 18 U.S.C. § 371 (Count II), and aiding in the preparation of his fraudulent income tax return for 1984 in violation of 26 U.S.C. § 7206(2) (Count III). The convictions are based on a complex series of financial...
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