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2 months later, claiming 99 withholding allowances; (c) in 1985,
claiming 99 withholding allowances; and (d) in 1987, claiming 10
withholding allowances and later 9 withholding allowances.
Petitioner concedes that the correct number of withholding
allowances for him during the years in issue was four. By
claiming an excessive number of withholding allowances,
petitioner eliminated a substantial amount of withholding for
1985 and 1987, and all withholding for 1986. Petitioner knew
or should have known that he was required to submit correct
Forms W-4 for the years in issue because, before the years in
issue, respondent assessed penalties against him for filing false
Forms W-4 for 1982.
Petitioner also submitted false Forms IL-W-4 for 1985, 1986,
and 1987, pertaining to withholding allowances for Illinois
income tax.
Petitioner contends that he honestly believed that he did
not have to pay tax, that the tax law was invalid as to wages,
and that paying income tax was voluntary. We disagree.
Petitioner did not try to contact a tax professional during the
years in issue. We do not believe that petitioner honestly
believed that he was not liable for tax for the years in issue.
Petitioner’s contention that he honestly believed that he
was not required to file returns and pay tax is inconsistent with
his plea agreement. In the plea agreement, he admitted that he
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