United States v. Rakow

MEMORANDUM*

Ronald L. Rakow appeals his conviction for tax evasion. 26 U.S.C. § 7201. We affirm.(1) Rakow asserts that because evidence of his failure to disclose loans to the Internal Revenue Service was admitted, there was constructive amendment of the indictment, or at least a variance. See United States v. Adamson, 291 F.3d 606, 614-15 (9th Cir.2002). We disagree. There was no plain error.1 His claim that the jury could not have founded its verdict on most of the overt acts set forth in the indictment because it acquitted him of other counts associated with those acts must fail. At most,…