MEMORANDUM OPINION AND ORDER
REBECCA BEACH SMITH, District Judge.
I. Procedural History
On December 10, 1990, Alan D. Gaskins, defendant in this action, pled guilty to a Criminal Information charging him with subscribing to a false income tax return for the year 1985, in violation of Title 26, United States Code, section 7206(1). Subsequently, on January 16, 1991, this court sentenced defendant to a term of three (3) years, ordering...
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