- 7 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011