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followed statements made by petitioner that he had made a mistake
in the way he handled the airline fares and the court's pointing
out to him that he must not only plead guilty, but must state
that he understood what he was doing, had consulted his attorney,
and understood the charges against him, and he must answer
questions that showed he understood that he was guilty. The
transcript of the guilty plea as a whole is not clear that
petitioner testified that at the time of the filing of his return
he knew that it was wrong to claim the deductions for airline
expenses. This is really the issue, not whether later petitioner
learned, and now knows, that the claiming of these expenses was
wrong. Although the person representing the U.S. attorney's
office and the court made it clear to petitioner that he would
have to admit knowing that the claiming of these expenses was
wrong, and he did admit that, never does it appear clearly that
he departs from his statement of making a mistake and intends to
be saying that he knew at the time he filed his returns that what
he did was wrong. There is, of course, by pleading guilty, the
inherent admission that he violated the provisions of section
7206(1), which provides that any person who willfully makes and
subscribes any return which contains or is verified by
declaration that it is made under penalty of perjury, and "which
he does not believe to be true and correct as to every material
matter" is guilty of a felony. However, the conviction under
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