United States v. Walter D. Brodie, United States of America v. Nancy A. Brodie

GOODWIN, Chief Judge:

I

Walter Brodie and his wife Nancy Brodie appeal their convictions under 26 U.S.C. § 7203 (1982 & Supp. II 1984) for willful failure to file income tax returns. We affirm.

Walter Brodie is a doctor and Nancy Brodie is a registered nurse. Between 1970 and 1986, they operated a medical practice together in the Reno/Lake Tahoe area. Nancy Brodie worked full time as a nurse for the medical practice during 1979 and 1980 while simultaneously serving as its accountant and bookkeeper. In 1979, Taxpayers earned more than $75,873 from their medical practice. In 1980, they earned more…