- 4 -
opened an account for each of his four children, and transferred
approximately $70,320 to each of these accounts.
In 1986, petitioner cashed a $50,000 certificate of deposit
and deposited the proceeds, together with additional funds, into
one of his bank accounts. On May 14, 1987, petitioner withdrew
$104,089.55 from this account and transferred approximately
$26,020 to each of his children's accounts.
II. Petitioner's Convictions
In early 1986, petitioner was arrested and charged with
gambling as a result of his participation in an illegal numbers
operation. On April 2, 1986, petitioner pled no contest. He was
found guilty, assessed a fine, and ordered to pay court costs.
On March 30, 1993, petitioner, pursuant to section 7201, was
charged with income tax evasion with respect to his 1986 and 1987
tax returns. On July 12, 1993, in the U.S. District Court for
the Northern District of Ohio, petitioner pled guilty to the
charges.
III. Respondent's Determinations
Petitioner filed his 1984, 1985, and 1986 Federal income tax
returns in a timely manner but filed his 1987 tax return 4 months
late. He reported gross income of $25,250.25, $24,615.67,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011