prov:value
| - nd assisting the preparation or presentation of afalse or fraudulent tax document, the defendant must ???[w]illfully aid[] or assist[] in,or procure[], counsel[], or advise[] the preparation or presentation under, or inconnection with any matter arising under, the internal revenue laws, of a return,affidavit, claim, or other document, which is fraudulent or is false as to any materialmatter, wheth
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