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Submitted: April 19, 2012

Before MURPHY, MELLOY, and GRUENDER, Circuit Judges.

Kenneth Edward Godat waived indictment and was charged by information with structuring financial transactions for the purpose of evading currency-transaction reporting requirements in violation of 31 U.S.C. § 5324(a)(3) and with evading taxes in violation of 26 U.S.C. § 7201. Both charges stem from Godat’s having fraudulently taken money from a victim whom he convinced to invest in an entirely fictional business that he claimed to operate. Godat had the victim withdraw cash in amounts just small enough to circumvent statutory reporting requirements, and he did not report as taxable income the money he was receiving from her and using for his own benefit.

 
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