KANNE, Circuit Judge.
On August 9, 1984, a grand jury in the Northern District of Illinois returned a sixteen count indictment against David A. Ruzzano. Counts fifteen and sixteen, at issue here, charged Ruzzano with tax evasion in violation of 26 U.S.C. § 7201 in the amount of $313,000 and $236,000 for the years of 1979 and 1980 respectively. The indictment was the result of an investigation into Ruzzano's participation in an oil swindle in which he allegedly...
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