T.C. Memo. 1996-204 UNITED STATES TAX COURT JAMES ALAN PRICE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23802-93. Filed April 29, 1996. In 1985, 1986, and 1987, P engaged in various tax protester activities, filed false Forms W-4, and did not file tax returns. R determined that P is liable for the addition to tax for fraud for those years. P was convicted of income tax evasion under I.R.C. sec. 7201 for 1986 and willful failure to file under I.R.C. sec. 7203 for 1987. P contends that imposition of the addition to tax for fraud violates his right not to be subject to double jeopardy under the Fifth Amendment of the U.S. Constitution. Held: P is liable for the addition to tax for fraud for 1985, 1986, and 1987. Held, further, imposition of the addition to tax for fraud against P for 1985, 1986, and 1987, after he was convicted of income tax evasion for 1986 andPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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