Ronald E. Reed - Page 7

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          87 T.C. 74, 76-77 (1986).  Therefore, petitioner bears the burden           
          of proving that respondent's determination of deficiencies is               
          erroneous.  Rule 142(a).                                                    
          II.  Deficiencies in Tax                                                    
               Petitioner assigns error to respondent’s determination of              
          deficiencies in tax on the grounds that respondent failed to                
          consider the nontaxable sources of the amounts expended for the             
          listed property.                                                            
               In 1989, petitioner was adjudged guilty of money laundering            
          and conspiracy to distribute cocaine.  At petitioner’s                      
          rearraignment on the charges that led to that judgment, the                 
          District Court was presented with the plea agreement and                    
          statement of facts, in which (when taken together) it is stated             
          that petitioner had received illegal earnings from trafficking in           
          cocaine, which were expended for certain property, including the            
          listed property.  During his rearraignment hearing, petitioner              
          agreed that the plea agreement and the statement of facts were              
          correct.  In this Court, however, petitioner asks us not to                 
          credit the plea agreement and statement of facts, claiming that             
          he entered into the plea agreement and agreed that the plea                 
          agreement and statement of facts were correct only to please the            
          Government and to avoid further prosecution.  He further claims             
          that he earned no cash income from drug sales, being paid for his           
          drug-connected activities in drugs that he consumed, and that the           





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