James Alan Price - Page 1

                                 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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