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the Fifth Amendment to the Constitution and refused to answer
some of Agent Burke's questions. For example, petitioner refused
to answer whether he had cash on hand as of December 31, 1983.
Petitioner also refused to answer questions about the source of
the income reported as "commissions" on his 1984 and 1985 Forms
1040.
Agent Burke served summonses on Connecticut National Bank
and the Bank of Screven County. These banks complied with the
summonses, and Agent Burke used the records to prepare the net
worth computations for the taxable years 1984 through 1986.
On June 1, 1992, petitioner waived his right to indictment
and pled guilty to an information charging him with one count of
willfully making and subscribing to a materially false Federal
income tax return for the taxable year 1985 in violation of
section 7206(1). On September 14, 1992, petitioner was sentenced
to 3 years' incarceration, suspended after 6 months, placed on 5
years' probation, and fined $10,000.
OPINION
The dispute in this case focuses on respondent's net worth
computations and respondent's fraud determinations. Petitioners
argue that respondent's net worth calculations are invalid due to
errors. Petitioners also contend that respondent has failed to
prove that petitioner is liable for the fraud additions to tax.
Petitioners dispute only four of the items in respondent's net
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