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his adjusted gross income and his tax liability. Subsequently,
petitioner pled guilty to the charge of violating section 7206(1)
for the year 1983 by knowingly filing a false income tax return
that "stated his air travel expenses were $38,465, * * * his
adjusted gross income was $17,503, whereas as he then and there
well knew and believed, he had no air travel expenses and his
adjusted gross income was $55,838, resulting in additional tax
due and owing of $14,050." Petitioner, through his attorney and
the representative of the U.S. attorney handling the case,
entered into a plea bargain agreement. When the case was called
and the court was informed of the plea bargain agreement,
petitioner stated that he had discussed his case with his lawyer
and wanted to enter the guilty plea to the year 1983 under the
plea bargain agreement. Petitioner, at the hearing, stated that
he had made a mistake, but when informed by the U.S. attorney and
the judge that it was necessary that he say that he had claimed
the deductions for air fare that he had not paid knowing that he
was not entitled to claim the deductions, he so stated.
Petitioner was permitted to continue to travel out of State to
wrestling matches between the time he entered the guilty plea and
the date of sentencing. The judgment and probation/commitment
order of the U.S. District Court was entered on May 4, 1990. It
provided that: "Imposition of sentence is suspended and the
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