The following excerpt is from United States v. Coppola, 425 F.2d 660 (2nd Cir. 1969):
1 Coppola entered his plea of guilty on the condition that he be allowed to contest the constitutionality of 7201 on appeal. See United States v. Grassia, 354 F.2d 27 (2d Cir. 1965), vacated on other grounds, 390 U.S. 202, 88 S.Ct. 899, 19 L.Ed.2d 1034 (1968).
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