OPINION
STAPLETON, District Judge:
On March 3, 1972 a grand jury indicted Louis Goldstein on three counts. Counts I and III charged that Mr. Goldstein and his wife, Selma, filed income tax returns for the years 1964 and 1966, respectively, which they did not believe to be true and correct as to every material matter in violation of Section 7206(1) of Title 26 of the United States Code. Count II charged Mr. Goldstein with willfully failing to make a timely...
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