Relying on Minarik, 875 F.2d 1186, the district court granted the motion to dismiss. United States v. Mohney, 723 F. Supp. 1197 (E.D.Mich. 1989). In Minarik, this court was concerned about the confusion caused to the defendants in that case by the failure of the indictment adequately to notify them of the charges.

We therefore reject Alexander's argument that Count I was defective because it failed to allege multiple conspiracies. Second, Alexander argues that Count I of the indictment is defective because it should have charged him with a conspiracy to commit a specific crime under 26 U.S.C. § 7206(1) (1988), rather than a conspiracy to defraud under 18 U.S.C. § 371. Alexander relies on United States v. Minarik, 875 F.2d 1186 (6th Cir. 1989), and United States v. Mohney, 723 F. Supp. 1197 (E.D.Mich. 1989). In Minarik, the defendants were charged with willfully conspiring to defraud the United States by impeding, impairing, obstructing, and defeating the lawful functions of the Department of the Treasury in violation of 18 U.S.C. § 371. 875 F.2d at 1188.

The district court dismissed this charge prior to trial. 723 F. Supp. 1197. The remaining counts named only Mohney. Counts II-IV charged Mohney with filing false individual income tax returns for the calendar years 1981-83, respectively, in violation of 26 U.S.C. § 7206(1). Counts V-VII charged that Mohney willfully aided and assisted in the filing of false corporate tax returns for Otis Mohney, Inc. ("OMI"), later IA, for the fiscal years 1982-84, respectively, in violation of 26 U.S.C. § 7206(2).