The following excerpt is from U.S. v. Touw, 769 F.2d 571 (9th Cir. 1985):
In United States v. Taylor, 716 F.2d 701, 712 n. 6 (9th Cir.1983), we noted that section 846 is ambiguous and that punishment for both attempt and conspiracy may be inappropriate if the defendants engaged in a single course of action. We reversed the attempt convictions on other grounds.
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