OPINION
FEIKENS, District Judge.
On November 19, 1993, a jury in the Eastern District of Michigan returned a verdict of guilty against Norbert Breinig on two counts of wilfully attempting to evade and defeat his federal income taxes for the years 1986 and 1987 in violation of 26 U.S.C. § 7201. Before me now is defendant Breinig's motion for a new trial. For the reasons stated below, that motion is denied.
I. Background
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