HOLMES, Circuit Judge.
Louis Hansen, a taxpayer who ascribes to legal theories associated with sovereign-citizen and tax-protester movements, was indicted for tax evasion in violation of 26 U.S.C. § 7201 and tax obstruction in violation of 26 U.S.C. § 7212(a). Before trial, Mr. Hansen purported to waive his right to counsel. The district...
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