OWEN, Senior District Judge.
In the years at issue, 1985 through 1988, appellant Don Gonzales owned and ran a small company in Burns Flat, Oklahoma, named Star Rotating Heads, Inc., which leased patented rotating drill heads for oil drilling to operating oil companies. In 1993 he was convicted by a jury in the District Court for the Western District of Oklahoma on two counts of knowingly and willfully attempting to evade the payment to the Internal Revenue Service...
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