Page G. Stuart - Page 5

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          All of the currency seized in this manner was in petitioner's               
          possession and/or subject to petitioner's dominion and control at           
          the time that it was seized.                                                
               During 1992, petitioner paid $26,000 in cash to a general              
          contractor for work done on a residence located in Nashville,               
          Tennessee.                                                                  
               During 1994, petitioner was convicted of Federal money                 
          laundering charges and was sentenced to 5 years in prison.  At              
          the same time, petitioner was convicted of conspiracy to                    
          distribute marijuana by the State of Tennessee.                             
               Petitioner failed to maintain, or submit to respondent for             
          examination, adequate books or records regarding the income that            
          he derived from sales of illegal drugs during the years in issue.           
          At the start of the 1992 taxable year and at all times during the           
          1992 and 1993 taxable years, petitioner neither had nor received            
          any nontaxable or excludable income, receipts, cash, or other               
          assets.                                                                     
               Petitioner realized income from sales of illegal drugs in              
          the amounts of $751,823 and $400,260 during the taxable years               
          1992 and 1993, respectively.                                                
               Petitioner filed individual Federal income tax returns for             
          1992 and 1993 reporting adjusted gross income (comprised of wage            
          and interest income from a checking account) of $10,933 and                 
          $6,169, respectively.  Petitioner failed to report any income               
          and/or expenses from illegal drug sales on his 1992 and 1993 tax            




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