UNITED STATES v. WELLS

No. 84-2573.

790 F.2d 73 (1986)

UNITED STATES of America, Plaintiff-Appellee, v. Jackson Buster WELLS, Defendant-Appellant.

United States Court of Appeals, Tenth Circuit.

May 9, 1986.


Attorney(s) appearing for the Case

John S. Newberry, Gladstone, Mo. (Cecil A. Hartman, Denver, Colo., was also on brief), for defendant-appellant.

Catharine M. Goodwin, Asst. U.S. Atty., Denver, Colo. (Robert N. Miller, U.S. Atty., Denver, Colo., was also on brief), for plaintiff-appellee.

Before HOLLOWAY, Chief Judge, and BARRETT, Circuit Judge.


HOLLOWAY, Chief Judge.

Defendant Wells was charged with willfully failing to file income tax returns under 26 U.S.C. § 7203 (1982). I R. 1-3. At trial, defense counsel conceded that Wells had not filed returns for the years 1977-1980, but argued that the failure to do so was the result of a mistaken interpretation of the tax laws. I R. 149 (Defendant's requested instruction no. 13); VII R. 58-67 (Defendant's closing argument...

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