United States v. Jackson Buster Wells

HOLLOWAY, Chief Judge.

Defendant Wells was charged with willfully failing to file income tax returns un der 26 U.S.C. § 7203 (1982). I R. 1-3. At trial, defense counsel conceded that Wells had not filed returns for the years 1977-1980, but argued that the failure to do so was the result of a mistaken interpretation of the tax laws. I R. 149 (Defendant’s requested instruction no. 13); VII R. 58-67 (Defendant’s closing argument). The court entered a judgment of conviction pursuant to a jury verdict, and this appeal followed. I R. 214; VII R. 89, 91.

In this appeal, the defendant presses the…