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U.S. v. Gollapudi, No. 97-5137 (3rd Cir.) (130 F.3d 66) (November 17, 1997) (Judge Jane R. Roth)

The issue in this case was whether a failure to "pay over" any taxes under 26 U.S.C. § 7202 constitutes a failure to "pay any tax, or make any return" within the meaning of the 26 U.S.C. § 6531(4). That latter statute provides that criminal tax proceedings must be initiated ...

 

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