Court of Appeals for the Second Circuit April 24, 1978, 341, Docket 77-1348 (United States v. Andrew Tsanas)

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FRIENDLY, Circuit Judge:

A grand jury in the District Court for the Eastern District of New York filed a five count indictment charging Andrew Tsanas and his wife, Pauline, with evading income taxes in violation of 26 U.S.C. § 7201

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for the five years 1971-1975. Pauline pleaded guilty to one count of willfully filing a false tax return in violation of 26 U.S.C.