McLAUGHLIN, Circuit Judge:
BACKGROUND
In February 1996, the government charged Milton Gottesman in a two-count information. Count One charged Gottesman with making a false Application for Automatic Extension of Time to File a United States Individual Tax Return, in each year from 1988 through 1991, in violation of 26 U.S.C. § 7206(1). Count Two charged him with failing to file income tax returns for 1988 through 1991, in violation of 26 U.S.C. §...
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