Court of Appeals for the Ninth Circuit October 15, 1991, 90-10473 (United States v. Lonnie Schmidt)

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.