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salesman told him that Caplan's alleged underworld friends were
going to harm petitioner.
On March 22, 1973, petitioner was indicted on two counts of
income tax evasion for the taxable years 1966 and 1967 and on one
count of willfully making and subscribing to a false income tax
return for the taxable year 1966. An arrest warrant was issued.
After being a fugitive from justice for some 16 years, petitioner
surfaced in early 1987. On July 31, 1987, petitioner pleaded
guilty to one count of income tax evasion pursuant to section
7201 for the taxable year 1967. The count to which he pleaded
guilty was that he had received taxable income of $92,168.61 in
1967 as to which he willfully and knowingly attempted to evade
taxes.
Petitioner's Federal Income Tax Returns
Petitioner filed a joint Federal individual income tax
return with Singer for the taxable year 1966. He reported his
dealership wages of $15,886.10 and no other income. The
signatures of both petitioner and Singer are dated April 17,
1967, but the envelope in which the return was mailed was
postmarked May 18, 1967. No extension of time for filing was
requested. Petitioner did not file a Federal individual income
tax return for the taxable year 1967.
Respondent used the specific-items method to determine
petitioner's unreported income from the car sales. Special Agent
Nahmias of the Criminal Investigation Division of the Internal
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