United States v. Amos Searan and Jeanettia Searan

OPINION

BOGGS, Circuit Judge.

On March 19, 1997, a grand jury handed up a 15-count indictment charging Jeanet-tia and Amos Searan with one count of conspiracy to file a materially false application to participate in the Electronic Filing Program (a violation of 26 U.S.C. § 7206(1)) and conspiracy to assist and advise others in the preparation and presentation of materially false income tax returns (a violation of 26 U.S.C. § 7206(2)), in violation of 18 U.S.C. § 371, and thirteen separate counts of assisting and advising others in filing materially false tax returns, in violation of 26 U.S.C. §…