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failure to file a return under section 7203 for 1985, 1986, and
1987. On June 10, 1992, petitioner pleaded guilty to income tax
evasion under section 7201 for 1986 and to willful failure to
file a return under section 7203 for 1987. In his plea
agreement, petitioner admitted that he attempted to evade Federal
income taxes by filing false Forms W-4 for 1985, 1986, and 1987.
His plea agreement stated in part as follows:
5. Defendant will plead guilty because he is in
fact guilty of the charges contained in Counts Three
and Five of the indictment. In pleading guilty to
these counts, defendant acknowledges that:
(a) as charged in Count Three of the
indictment, during calendar year 1986, defendant had
gross income of $56,761 and taxable income of $52,441.
Upon that income, defendant owed at least $11,691 in
income taxes to the United States. Defendant knew that
he was required by law on or before April 15, 1987 to
make an income tax return to the Internal Revenue
Service and to pay his income tax. Defendant wilfully
failed to file an income tax return and failed to pay
his income taxes on or before April 15, 1987.
Defendant further acknowledges that he did not file his
1986 tax return until August 1990. In addition,
defendant attempted to evade the payment of income
taxes for the calendar year 1986 by submitting a false
Employee's Withholding Allowance Certificate (Form W-4)
in which he falsely claimed that he was entitled to
ninety-nine withholding allowances, in order to prevent
his employer from withholding the proper amount of
income tax from his pay.
(b) as charged in Count Five of the
indictment, defendant had gross income of approximately
$34,382 in the calendar year 1987, which included
payments he received for his services as an
electrician. Defendant knew that he was required to
make an income tax return to the Internal Revenue
Service on or before April 15, 1988, and wilfully
failed to make the required income tax return to the
Internal Revenue Service or to any other proper officer
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