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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. § 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.