United States v. Sorkis J. Webbe

NELSON, Circuit Judge:

Sorkis J. Webbe appeals his jury conviction on two counts of making and filing a false income tax return in violation of 26 U.S.C. § 7206(1). Webbe, along with several others, had earlier been acquitted of conspiracy to defraud a union pension fund (United States v. Linton, CR-80-24-ECR). Webbe argues that the government was barred by collateral estoppel from trying him on the tax charges, because of his earlier acquittal on the conspiracy charges. Next, Webbe asserts that the district court erred in admitting certain evidence under Fed.R.Evid. 801(d)(2)(E). Finally, he…