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PER CURIAM: Appellant was convicted for willful failure to file federal income tax returns in violations of 26 U.S.C. ยง 7203 (1976). His contention that the district court had no subject matter jurisdiction over the offense is frivolous. U.S. v. Spurgeon, 671 F.2d 1198 (8th Cir.1982); U.S. v. Marks, 534 F.Supp. 663 (W.D.Mo.1982). AFFIRMED.