Court of Appeals for the Ninth Circuit September 17, 1997, 94-10579 (United States v. Harold H. Uchimura)

ORDER

Appellee’s petition for rehearing is granted. The opinion filed February 25,1997, and published at 107 F.3d 1321, is withdrawn and the attached opinion is filed in its place.

OPINION

REED, District Judge:

Appellant Harold H. Uchimura (“Uehimura”) appeals his conviction for filing a materially false tax return in violation of 26 U.S.C. § 7206(1).