Adnan Al Kaissy - Page 24

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            followed statements made by petitioner that he had made a mistake                          
            in the way he handled the airline fares and the court's pointing                           
            out to him that he must not only plead guilty, but must state                              
            that he understood what he was doing, had consulted his attorney,                          
            and understood the charges against him, and he must answer                                 
            questions that showed he understood that he was guilty.  The                               
            transcript of the guilty plea as a whole is not clear that                                 
            petitioner testified that at the time of the filing of his return                          
            he knew that it was wrong to claim the deductions for airline                              
            expenses.  This is really the issue, not whether later petitioner                          
            learned, and now knows, that the claiming of these expenses was                            
            wrong.  Although the person representing the U.S. attorney's                               
            office and the court made it clear to petitioner that he would                             
            have to admit knowing that the claiming of these expenses was                              
            wrong, and he did admit that, never does it appear clearly that                            
            he departs from his statement of making a mistake and intends to                           
            be saying that he knew at the time he filed his returns that what                          
            he did was wrong.  There is, of course, by pleading guilty, the                            
            inherent admission that he violated the provisions of section                              
            7206(1), which provides that any person who willfully makes and                            
            subscribes any return which contains or is verified by                                     
            declaration that it is made under penalty of perjury, and "which                           
            he does not believe to be true and correct as to every material                            
            matter" is guilty of a felony.  However, the conviction under                              

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