No. 90-10060.

936 F.2d 1056 (1991)

UNITED STATES of America, Plaintiff-Appellee, v. Roy G. POWELL; Dixie Lee Powell, Defendants-Appellants.

United States Court of Appeals, Ninth Circuit.

Decided June 13, 1991.

Attorney(s) appearing for the Case

Michael Louis Minns, Houston, Tex., for defendants-appellants.

Yoel Tobin, U.S. Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before TANG, FLETCHER and REINHARDT, Circuit Judges.

TANG, Circuit Judge:

Roy and Dixie Lee Powell appeal their jury convictions for the willful failure to file income tax returns in violation of 26 U.S.C. § 7203. The dispositive issues are whether the district court erred in its jury instructions and in limiting evidence that the Powells could present.1 More specifically, we address whether the district court erred in (1) its instruction on willfulness, (2) refusing to allow an instruction...

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