United States v. Shermetaro, 625 F.2d 104 (6th Cir. 1980); Mertens, The Law of Federal Income Taxation 14, Ch. 55A.10 (1988). And of course numerous cases have recognized that more detailed statutes criminalizing substantive acts, enacted after § 371, do not impliedly repeal or preempt the prohibition on conspiracy to commit those acts contained in § 371. United States v. Little, 753 F.2d 1420 (9th Cir. 1984); United States v. Zang, 703 F.2d 1186 (10th Cir. 1982), cert. denied, 464 U.S. 828, 104 S.Ct. 103, 78 L.Ed.2d 107 (1983); United States v. Tarnopol, 561 F.2d 466 (3d Cir. 1983); United States v. Bazzell, 187 F.2d 878 (7th Cir.), cert. denied sub nom. Lasby v. United States, 342 U.S. 849, 72 S.Ct. 73, 96 L.Ed. 641 reh'g denied, 342 U.S. 889, 72 S.Ct. 171, 96 L.Ed. 667 (1951); Burton v. United States, 175 F.2d 960 (5th Cir. 1949); United States v. Pezzati, 160 F. Supp. 787 (D.Colo. 1958).
" This Court said in United States v. Bazzell, 7 Cir., 1951, 187 F.2d 878, 884: "As to the argument that the verdict is inconsistent, it will be enough to say that where a defendant is charged by two or more counts in an indictment, consistency between the verdicts on the several counts is not necessary. Dunn v. United States, 284 U.S. 390, 52 S.Ct. 189, 76 L.Ed. 356; United States v. Denny, 7 Cir., 165 F.2d 668; and United States v. Coplon, 2 Cir., 185 F.2d 629, 633, 28 A.L.R.2d 1041. A verdict of acquittal on one count does not invalidate a verdict of guilty on another count, although the same evidence is offered in support of each. Garrison v. Hunter, 10 Cir., 149 F.2d 844, 845.
Whatever intimations defendant envisages this Court as having made in United States v. Moloney, 7 Cir., 1952, 200 F.2d 344, 346, the case is unavailing here on Morris' contention that the jury returned inconsistent verdicts. We recognized the value of United States v. Bazzell, 7 Cir., 1951, 187 F.2d 878, in our Moloney opinion and apply it here. Careful consideration of those remarks, challenged here by defendant, made to jurors by the district judge during the voir dire examinations has shown us there is absent any sound reason for overturning the jury's verdict.
See to same effect Robinson v. United States, 9 Cir., 175 F.2d 4, 9, 10, wherein it was pointed out that nothing in the Sealfon case applies to verdicts which are all received at the same time in a single trial. See also Pilgreen v. United States, 8 Cir., 157 F.2d 427, 428. Cf. Young v. United States, 10 Cir., 168 F.2d 242, 246; United States v. Bazzell, 7 Cir., 187 F.2d 878, 884. In Coplin v. United States, 9 Cir., 88 F.2d 652, 661, it was held that, inasmuch as verdicts on different counts in an indictment need not be consistent, acquittal on a count charging conspiracy did not have the effect of preventing the acts of each defendant from being admissible against others under a substantive count not charging conspiracy.