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 and
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