OPINION
RONALD LEE GILMAN, Circuit Judge.
Edward Fisher was convicted under 18 U.S.C. § 371 of conspiracy to defraud the United States while serving as in-house general counsel to Simplified Employment Services, Inc. (SES). The conspiracy that led to Fisher's conviction involved SES's filing of false tax returns with the Internal Revenue Service (IRS). Fisher was implicated in the conspiracy based on, among other things, his role as the liaison to SES...
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