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reported the following amounts of gross income for the taxable
years at issue:
Year Gross Income
1980 $77,539
1981 70,185
1982 60,665
1983 57,343
1984 104,827
1985 55,367
1986 66,994
The tax returns petitioner filed for each taxable year at
issue include a Schedule B. Each Schedule B specifically
inquires as to whether petitioner maintained a foreign bank
account at any time during the corresponding taxable year.7
Instructions contained on each Schedule B require the answer to
this inquiry to be indicated by marking a box labeled either
"Yes" or "No." Petitioner left the blocks corresponding to this
inquiry blank on his returns for each taxable year at issue,
except years 1984 and 1985. With respect to taxable years 1984
and 1985, petitioner explicitly indicated on each Schedule B that
he did not maintain a foreign bank account at any time during the
year.
On October 5, 1992, petitioner, in accordance with a plea
agreement, pleaded guilty to and was convicted of filing false
individual income tax returns for taxable years 1985 and 1990, in
7Respondent states on brief that petitioner's returns for
1982 and 1986 did not specifically make this inquiry; however, an
examination of those returns shows respondent to be in error.
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