Court of Appeals for the Sixth Circuit December 26, 1985, 84-1668 (United States v. Michael Popenas)

BOYCE F. MARTIN, JR., Circuit Judge.

Michael Popenas was convicted of four counts of income tax evasion in violation of 26 U.S.C. § 7201. The only question at trial was whether Popenas’ failure to report substantial amounts of income during the years 1977 to 1980 was willful, as required by the statute. Popenas appeals two evidentiary rulings of the district court bearing on willfulness.