ORDER
Appellee's request for publication is granted. The Memorandum filed January 28, 1998, is redesignated as an authored opinion by Judge Sedwick.
OPINION
SEDWICK, District Judge.
INTRODUCTION
Oghenerho Omene ("Omene") raised suspicions at the Internal Revenue Service ("IRS") office in Hayward, California, by filing, as a tax preparer, tax returns with unusual similarities. An IRS investigation resulted in the identification...
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