MARSH, District Judge.
The defendants, Sigal and Rabinovitz, were convicted after a jury trial of (1) willfully attempting to evade and defeat the excise tax on wagers for the month of November, 1961, 26 U.S.C.A. § 7201; (2) two counts of willful failure to pay the special tax imposed on persons engaged in the business of accepting wagers and in the receiving wagers for or on behalf of a person or persons engaged in the business of accepting wagers, 26 U.S.C...
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