- 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
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