MEMORANDUM AND ORDER
DeMASCIO, District Judge.
The defendant operated two service stations in Detroit, Michigan, selling gasoline products retail to the general public. For calendar year 1982, defendant underreported his gross receipts and, correspondingly, underpaid his state sales tax liability by approximately $240,000. In August 1983, defendant was charged in a 12-count information in Recorder's Court with failure to pay the sales tax. He was tried,...
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