MEMORANDUM
CALDWELL, District Judge.
Introduction
The defendant has been charged with three counts of income tax evasion in violation of section 7201 of the Internal Revenue Code, 26 U.S.C. § 7201. On September 2, 1987, the court conducted a non-jury trial, at the completion of which the parties were requested to prepare and file briefs on the facts and the law. Upon careful consideration of the evidence presented at trial and the arguments...
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