United States v. Rao Gollapudi

OPINION OF THE COURT

ROTH, Circuit Judge.

I. INTRODUCTION

This is an appeal from a twelve-count indictment charging the defendant, Rao Golla-pudi, with violating two provisions of the Internal Revenue Code. More specifically, Gollapudi was charged with failing to account for and pay over to the Internal Revenue Service federal income taxes, deducted and collected from the total taxable wages of his employees, between 1989 and 1991, in violation of 26 U.S.C. § 7202. Additionally, Golla-pudi was indicted for filing a false personal income tax return, Form 1040, for the years 1989 through 1991, in…