SMITH, Circuit Judge.
A jury found Peter A. Giambalvo guilty of one count of corruptly obstructing or impeding the administration of the internal revenue laws, in violation of 26 U.S.C. § 7212(a) ("Count 1"), and eight counts of willfully filing a false income tax return, in violation of 26 U.S.C. § 7206(1) ("Counts 2-9"). The district...
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