United States v. Thomas W. Tierney

*857McMILLIAN, Circuit Judge.

Thomas W. Tierney (“defendant”) appeals from a final judgment entered in the United States District Court1 for the Western District of Missouri upon a jury verdict, finding him guilty of one count of conspiracy to defraud the United States in violation of 18 U.S.C. § 371 (1988), and fifteen counts of assisting in the preparation of materially false income tax returns in violation of 26 U.S.C. § 7206(2). The district court sentenced him to three years in prison, a $10,000 fine, payment of the costs of prosecution, and two years of probation. For reversal, defendant…