What are the implications of a finding that a jury convicted a defendant of a tax evasion charge against him in his personal income tax case?

The jury convicted Selivanov of violating Revenue and Taxation Code section 19705, subdivision (a)(1) with respect to his personal income taxes for the years 2004-2008. Selivanov contends these convictions cannot stand because they were "follow-on charges that were wholly dependent on liability for" other substantive charges, the embezzlement convictions in counts 2, 19, 22, and 25. That is, the People alleged that Selivanov failed to report as income the money he embezzled in counts 2, 19, 22, and 25. (See People v. Hagen (1998) 19 Cal.4th 652, 671 ["it has long been settled law that embezzled funds are taxable income"].) Selivanov argues that reversal of the embezzlement convictions also must result in reversal of the convictions for willfully filing false or fraudulent personal tax returns. This argument cannot succeed in light of our rulings above sustaining the embezzlement counts.