MANION, Circuit Judge.
On June 11, 1991, a federal grand jury returned a superseding indictment against Mark A. Chevalier alleging three counts of tax fraud, 26 U.S.C. § 7206(1), and two counts of making false statements in connection with loan extensions, 18 U.S.C. § 1014. On November 1, 1991, the district court granted Chevalier's motion to sever the tax and bank fraud counts. At the close of trial, the jury convicted Chevalier of the three tax fraud counts...
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