James Alan Price - Page 3

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               2.   Whether the imposition of additions to tax for fraud              
          against petitioner under section 6653(b) for 1985, 1986, and                
          1987, after petitioner’s conviction for income tax evasion under            
          section 7201 for 1986 and willful failure to file under section             
          7203 for 1987, violates the Double Jeopardy Clause of the Fifth             
          Amendment.  We hold that it does not.                                       
               Section references are to the Internal Revenue Code as in              
          effect for the years in issue.  Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner lived in Minooka, Illinois, when he filed the               
          petition in this case.                                                      
               Petitioner was born on January 22, 1955.  He graduated from            
          high school in 1973.  He has been married to Barbara Price since            
          1973.  They have three children:  Lee, Eric, and Ana.  Lee and              
          Eric were dependents of petitioner and his wife during the years            
          in issue.  Ana was born after the years in issue.                           
               From 1973 to 1977, petitioner was an apprentice electrician            
          with the International Brotherhood of Electrical Workers,                   
          studying and working to become a journeyman electrician.  In                
          1977, petitioner became a journeyman electrician.  From 1977                
          until the time of trial, he worked as a journeyman electrician              





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