Court of Appeals for the Ninth Circuit January 22, 1993, 91-50090 (United States v. Kent Borden Rogers)

O’SCANNLAIN, Circuit Judge:

Rogers pled guilty to mail fraud and was sentenced to eight years imprisonment and ordered to pay $70.7 million in restitution. The government concedes that the imposition of restitution was improper, but the parties disagree on the proper remedy. Rogers also contends that his plea was coerced by the imposition of an IRS jeopardy assessment.