No. 89-658.

498 U.S. 192 (1991)


Supreme Court of the United States.

Decided January 8, 1991.

Attorney(s) appearing for the Case

William R. Coulson argued the cause for petitioner. With him on the briefs was Susan M. Keegan.

Edwin S. Kneedler argued the cause for the United States. With him on the brief were Solicitor General Starr, Assistant Attorney General Peterson, Deputy Solicitor General Bryson, Robert E. Lindsay, and Alan Hechtkopf.

JUSTICE WHITE delivered the opinion of the Court.

Title 26, § 7201 of the United States Code provides that any person "who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof" shall be guilty of a felony. Under 26 U. S. C. § 7203, "[a]ny person required under this title . . . or by regulations made under authority thereof to make a return . . . who willfully fails to . . . make such return" shall be guilty...

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