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U.S.C. § 7206(1).1 The govern- ment alleges that Harvey kept millions of dollars derived from his lucrative drug dealings in a bank account in the Cayman Islands. In his individual income tax re- turn for the year 1980, however, Haney denied that he had any proprietary interest in, or authority over
ON For the reasons we have stated above, we REVERSE the decision of the district court and REMAND for proceedings con- sistent with this opinion. CLARK, Circuit Judge, dissenting: The majority has written a well reasoned opinion on the scope of formal statutory immunity. Insofar as the court holds
ity, and do not face any different 'species' of immunity—e.g., an express agreement not to prosecute for future tax violations with respect to the Cayman Is- lands." Supra at 1446 n. 10. Indeed as I read the majority opinion, its holding that Harvey's immunity is only as broad as the fifth amendment
Beach, Fla., for plaintiffs-appellees. Appeal from the United States District Court for the Southern District of Florida. Before HILL, VANCE and CLARK, Circuit Judges. EFTA00191793 Page 1 of 3 Westlaw. CJS INJUNCTION § 281 43A C.J.S. Injunctions § 281 Corpus Juris Secundum Database updated
he arrearage while maintain- ing his monthly mortgage payments, he probe- income tax returns with respect to interest income from funds deposited in Cayman Islands account was entered in the United States District Court for the Southern Dis- trict of Florida, No. 85-06204, James C. Paine, J., 651 F.Su
istrict Court for the Southern District of Florida. Before RONEY, Chief Judge, TJOFLAT, HILL, FAY, VANCE, KRAVITCH, JOHNSON, HATCHETT, ANDERSON, CLARK, EDMONDSON, and COX, Circuit Judges. KRAVITCH, Circuit Judge: Appellee Jerry Lee Harvey disclosed his illegal activities in the drug trade to Dru
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