McWILLIAMS, Circuit Judge.
Leonard L. Payne was found guilty by a jury on four counts of failure to file income tax returns for the years 1979, 1980, 1981, and 1982, in violation of 26 U.S.C. § 7203. Payne was sentenced to one year imprisonment on the first count, fined $5,000 on the second count, fined an additional $5,000 on the third count and placed on three years probation on the fourth count.
On appeal, Payne urges two grounds for reversal: (1)...
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