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Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6654(a)
1990 $23,981 $17,986 $1,577
1991 22,695 17,021 1,306
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
The issue to be decided is whether respondent's
determination of the deficiencies in and additions to income tax
violates the Double Jeopardy Clause of the Fifth Amendment to the
U.S. Constitution.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of facts and the exhibits attached thereto are
incorporated herein by this reference. Petitioner's mailing
address was Philadelphia, Pennsylvania, at the time he filed his
petition in this case.
On January 12, 1993, petitioner was indicted on nine counts,
involving conspiracy to distribute cocaine, possession with
intent to distribute heroin, Federal income tax evasion for
failure to file returns for 1990 and 1991,1 money laundering and
aiding and abetting, including the knowing use of the proceeds of
1 These counts charged that petitioner "did willfully and
knowingly attempt to evade and defeat a large part of the income
tax due and owing by him * * * by failing to file an individual
income tax return" for the calendar years 1990 and 1991.
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