OPINION
HENDLEY, Judge.
Convicted of eighteen counts of attempt to evade or defeat any tax pursuant to § 72-13-85, N.M.S.A. 1953 (Repl. Vol. 10, pt. 2, 1961, Supp. 1975) and eight counts of willfully making a false return with intent to evade or defeat payment of the tax pursuant to § 72-13-86, N.M.S.A. 1953 (Repl. Vol. 10, pt. 2, 1961, Supp. 1975) defendant appeals. The points for reversal
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