Bruce P. Cadwell - Page 4

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          1988           Sandstrom Plumbing & Heating  18,794.71                      
          1988           Wayne R. Sandstrom Et al. Ptr.  3,287.00                     
                              Total 1988               22,081.71                      
               Petitioner filed Form W-4 with exempt status during the                
          years 1983, 1984, 1985, 1987, and 1988, claiming he owed no tax             
          in each of the prior years and expected to owe no income tax for            
          the current year.  Petitioner requested his union to withhold               
          information from the Internal Revenue Service (IRS).  The                   
          majority of petitioner's paychecks were signed over to a third              
          party in an attempt to conceal transactions from the IRS.                   
               Petitioner was the defendant in the criminal case of United            
          States v. Cadwell, Docket No. A91-0022CR (D. Alaska 1991).                  
          Respondent herein is a party in privity with the United States,             
          the prosecuting party in the aforesaid case.  In that case,                 
          petitioner was indicted on four counts of income tax evasion, in            
          violation of section 7201.  On July 1, 1991, petitioner entered a           
          plea of guilty to counts III and IV of the indictment for the               
          charged offense of Attempted Evasion of Income Tax relating to              
          his personal income tax returns for tax years 1986 and 1987.                
               The District Court accepted petitioner's guilty plea to                
          counts III and IV of the indictment upon being satisfied that               
          there was adequate factual basis that petitioner did willfully              
          attempt to evade and defeat part of his income tax for the                  
          taxable years 1986 and 1987, and was therefore guilty as charged.           
          Petitioner was convicted on his guilty plea, and the judgment is            
          final.                                                                      




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