AINSWORTH, Circuit Judge:
Appellants Dr. Sherman Merritt and Lupe Merritt were found guilty, after a jury trial, on three counts each of an indictment charging failure to file income tax returns in violation of 26 U.S.C. § 7203. They appeal their conviction, asserting the district court erred in failing to grant their motion for acquittal on the grounds 1) that there was insufficient evidence to show that Sherman Merritt was willful in failing to file a tax return...
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