- 2 - Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure, with the exception of references to rule 6(e), which are made to that provision as contained in the Federal Rules of Criminal Procedure. Background Some of the facts have been stipulated. The parties' stipulation of facts and the accompanying exhibits are incorporated by this reference. Petitioners, Sam F. Ford (hereinafter referred to as petitioner) and Ingrid Doorn Ford, resided in Eugene, Oregon, when they filed their petition in this case. Criminal Proceedings Against Petitioner On November 15, 1990, petitioner pled guilty, in the U.S. District Court for the Southern District of New York, Case No. 90 Cr. 777 (WK), to one count of making a false statement to the Securities and Exchange Commission, pursuant to 18 U.S.C. sec. 1001, and to one count of filing a false tax return for the taxable year 1986, pursuant to section 7206(1). In his allocution incident to the guilty plea, petitioner stated: In this 1986 federal personal income tax return, I failed to include income in excess of $2.8 million dollars I had received from the sale of securities belonging to me which I had secreted in accounts in the name of my son and others. The income, however, was reported on my son's 1986 personal tax return and the tax was fully paid through him.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011