OPINION
CLARY, Senior District Judge.
This is a net worth prosecution under 26 U.S.C. § 7201 for willful attempt to evade or defeat payment of income tax. The defendant, William A. Goichman, a cash basis taxpayer, is an attorney who formerly practiced law in Philadelphia. He now resides in Beverly Hills, California.
On September 10, 1974, the grand jury handed up a two-count indictment charging the defendant with attempting to evade payment...
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