CUMMINGS, Chief Judge.
Defendant Horace E. Bressler was convicted after a jury trial of two counts (Count One and Count Three) of willfully failing to file income tax returns for taxable years 1977 and 1978, in violation of 26 U.S.C. § 7203, and one count (Count Two) of willfully evading substantial tax liability for 1978, in violation of 26 U.S.C. § 7201. Defendant has timely appealed, and we affirm his conviction.
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