J. BLAINE ANDERSON, Circuit Judge:
I. THE FACTS
Edward Callery appeals his conviction of two counts of failure to file income tax returns in violation of 26 U.S.C. § 7203. Callery claims that (1) there was insufficient evidence of willfulness, generally, to convict him of willful failure to file a tax return pursuant to 26 U.S.C. § 7203; and (2) his good faith misunderstanding of the law negates the element of willfulness necessary for a conviction...
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