Wesley Snipes has appealed his three-year prison sentence on U.S. federal tax charges - insisting the term is "unreasonable."
The star was convicted in 2008 of three misdemeanor counts of willful failure to file his income tax return.
According to prosecutors, who pursued the maximum penalty, Snipes made at least $13.8 million for the years in question and owed $2.7 million in back taxes.
Snipes apologised at the time, insisting he was was "unschooled in the science of law and finance".
In a Georgia Court of Appeals on Friday his attorney accused prosecutors of seeking to make an example out of the actor, insisting the sentence "focused too heavily on deterrence".
Snipes' attorney also argued the actor should have been granted a hearing to decide whether his trial should have been in New York instead of Florida, where he has homes.
Snipes remains free on bail and was not present at the Atlanta courthouse.
The three-judge panel did not issue an immediate decision.
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