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U.S. v. SCHMIDT

No. 90-10473.

947 F.2d 362 (1991)

UNITED STATES of America, Plaintiff-Appellee, v. Lonnie SCHMIDT, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided October 15, 1991.

Attorney(s) appearing for the Case

William A. Cohan and Jennifer A. Greene, Cohan & Greene, Encinitas, Cal., for defendant-appellant.

Daniel S. Linhardt, Asst. U.S. Atty., Sacramento, Cal., for plaintiff-appellee.

Before CHAMBERS, Senior Circuit Judge, SNEED, Circuit Judge, and KELLEHER, District Judge.

KELLEHER, District Judge:

I. Factual and Procedural Background

Internal Revenue Special Agent Richard Carl was contacted in August 1985 by Internal Revenue Agent Mulholland to investigate appellant Lonnie Schmidt. Carl posed as a Northern California representative in charge of collections for an organized crime gambling interest from Las Vegas. Carl and the Internal Revenue Service had learned that the appellant, along with Herbert Bates, had failed to file...

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