BALDOCK, Circuit Judge.
In March 1994, a jury convicted Plaintiff Jerry V. Rice on two counts of filing a false tax refund claim and three counts of making and subscribing a false tax return in respective violation of 18 U.S.C. § 287 and 26 U.S.C. § 7206(1). The district court imposed a thirty-month term of imprisonment on Rice, ordered him to pay restitution, and fined him $20,000.
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