United States v. Brian W. Nelson

Brian W. Nelson was charged with two counts of failure to file income tax returns for 1978 and 1979, in violation of 26 U.S.C. § 7203. A jury found him guilty of both counts following trial in June 1983. The court 1 sentenced Nelson to two months in custody plus a $5,000.00 fine. Nelson also received a one year suspended sentence and three years of probation. This is a direct appeal from the conviction. For the reasons set forth below, we affirm.

In the summer of 1978, the Internal Revenue Service opened a criminal investigation into Brian Nelson’s failure to file income tax returns for the…