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Note: Michael Ioane (Defendant) appealed a prior conviction for federal tax fraud conspiracy and misrepresentation of fictitious United States financial instruments under 18 U.S.C. § 514. The U.S. Court of Appeals for the Ninth Circuit, Goodwin, O'Scannlain and Smith, J.J., in a Memorandum Opinion, ruled that there was sufficient evidence for the conviction and affirmed.

Defendant was found guilty of fraudulently preparing "Bills of Exchange" that the prior court found fell within the scope of 18 U.S.C. § 514(a)(2). The Bills referred to apparent values, dates, serial numbers, and the "Department of Treasury Foreign Letters of Credit Division".

Defendant claimed there was lack of evidence that his Bills of Exchange fictitiously misrepresented governmental financial instruments.

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