The following excerpt is from U.S. v. Kimball, 896 F.2d 1218 (9th Cir. 1990):
The government must establish three elements to prove willful failure to file an income tax return in violation of 26 U.S.C. Sec. 7203. 1 It must show that a taxpayer was required to file a return, that he failed to file a return, and that his failure to file was willful. United States v. Brodie, 858 F.2d 492, 497 (9th Cir.1988).
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