RULING ON MOTION TO DISMISS
JOSÉ A. CABRANES, District Judge:
This criminal prosecution for failure to file federal income-tax returns in violation of 26 U.S.C. § 7203 is before the court on the defendant's motion to dismiss. The defendant seeks dismissal of the charges against him on the asserted grounds of selective prosecution, equitable estoppel and violation of his right to substantive due process of law under the Fifth Amendment to the United...
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