Michael James Heun - Page 3

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          thereafter file a return for that year claiming "married filing             
          separate" status.  Petitioner did not timely file returns for               
          1984, 1985, 1986, 1987, and 1988.                                           
               On November 20, 1990, petitioner was convicted by a jury of            
          attempting to evade or defeat tax for 1983 under section 7201 and           
          of willfully making and subscribing a false return for the same             
          year under section 7206(1).  On the same date, petitioner was               
          convicted by a jury of willfully failing to file returns for                
          1984, 1985, 1986, 1987, and 1988 under section 7203.  The U.S.              
          Court of Appeals for the Ninth Circuit affirmed those convic-               
          tions.                                                                      
               After serving a portion of his sentence for the foregoing              
          crimes, petitioner was placed on probation.  As one of the                  
          conditions of that probation, petitioner was required to file a             
          return for each of the years 1984 through 1988.  As required by             
          law, petitioner was to report in those returns his wages from               
          employment during those years as well as other income and deduc-            
          tions.                                                                      
               On or about August 5 or August 9, 1993, petitioner filed               
          returns for the years 1984 through 1988 with the Internal Revenue           
          Service Center in Austin, Texas (Austin Service Center).  Each of           
          those returns bore petitioner's signature and the words "without            
          prejudice" appeared above his signature.  Petitioner claimed                
          "married filing separately" status in each of the returns for the           
          years 1984 through 1988 and reported total income from wages for            




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