Citation. United States v. Brown, 548 F.2d 1194, 1977 U.S. App. LEXIS 14234, 77-1 U.S. Tax Cas. (CCH) P9278, 39 A.F.T.R.2d (RIA) 1138, 1 Fed. R. Evid. Serv. (Callaghan) 847 (5th Cir. Fla. Mar. 18, 1977)
Brief Fact Summary. The defendant was charged with committing fraud in the preparation of other peoples’ tax returns. He appealed his conviction. The defendant argued that the testimony of the Internal Revenue Service (“IRS”) agent, made without entering the tax returns into evidence, that 90.