FAGG, Circuit Judge.
Tax accountants and former business partners Emile Rabinowitz and Gary Rieland designed a convoluted series of financial transactions, including wire transfers, to divert $701,000 from a client and to conceal the diversion from the client and the Internal Revenue Service (IRS). Rabinowitz and Rieland did not pay income taxes on the fraud income. The IRS eventually unraveled the scheme, and in Count I of a multicount indictment, the Government...
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