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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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