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years in issue and all Rule references are to the Tax Court Rules
of Practice and Procedure.
Petitioner, Frederick E. Slater, resided in Saratoga,
California, at the time the petition in this case was filed. On
February 18, 1992, the grand jury of Santa Clara County,
California, indicted petitioner on three counts of violation of
26 U.S.C. section 7201 (1982) for each of the years 1985, 1986,
and 1987. In each count, the grand jury charged petitioner with
willfully attempting to evade income tax liability by
underreporting the amount of taxes knowingly owed. On November
17, 1992, petitioner was found guilty on all three counts of the
indictment. He was sentenced to 4 months' imprisonment and 2
years of supervised release, including 4 months of electronic
home detention, and fined $2,300 and "the cost of prosecution in
this case", $2,231.
After termination of the criminal proceeding, the IRS
attempted to conduct a civil audit of petitioner's income tax
returns for the years 1985, 1986, and 1987. Petitioner, through
his then-attorney, refused to provide books and records to the
auditors and asked that the notice of deficiency be issued
immediately. After the present Tax Court cases were docketed,
petitioner supplied the books and records to the IRS Appeals
Office.
The parties have stipulated that the deficiencies in income
tax due from petitioner for 1985, 1986, and 1987 are $614,
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