348 F.3d 509 UNITED STATES of America, Plaintiff-Appellant,v.Patrick M. Donovan, Defendant-Appellee. No. 02-3260 United States Court of Appeals, Sixth Circuit. Submitted: June 17, 2003. Decided and Filed: October 31, 2003. Pursuant to Sixth Circuit Rule 206 ON BRIEF: Robert J. Branman, David English Carmack, UNITED STATES DEPARTMENT OF JUSTICE, TAX DIVISION, APPELLATE SECTION, Washington, D.C., […]