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1981 and 1982 taxable years, respectively, by filing false and
fraudulent U.S. individual income tax returns in violation of
section 7201, and conspiracy to defraud the U.S. Government by
hindering the function of the Internal Revenue Service in its
efforts to collect income taxes. On May 19, 1989, the District
Court for the District of Rhode Island, following a trial upon
the merits, entered a judgment of guilty on the first two
charges, regarding income tax evasion, and not guilty on the
conspiracy charge.
Among the issues of fact determined in connection with the
tax charges was whether petitioner did in fact willfully file
false and fraudulent income tax returns for 1981 and 1982 with
the intent to evade and defeat income tax, and whether he did in
fact by such means understate a part of the income tax due and
owing by him to the United States for each of the years.
Petitioner was sentenced to 3 years of imprisonment for each
of the Travel Act charges, to run concurrently, and 15 months'
imprisonment on the first tax evasion charge, to run
consecutively to the aforesaid sentence. For the remaining tax
evasion charge, petitioner received a 2-year suspended sentence
and was placed on probation consecutive to the expiration of the
aforesaid terms of imprisonment. Petitioner was also ordered to
pay a fine of $10,000 to the United States.
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