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an unlawful activity with the intent to conceal and disguise the
proceeds by utilizing such proceeds to acquire designated
property.
On February 5, 1993, petitioner pleaded guilty to all of the
above counts. As part of the plea agreement, petitioner also
consented to forfeit to the U.S. Government, under 21 U.S.C. sec.
853(a)(1994), all assets which were derived from proceeds of his
illegal drug activities, including but not limited to: $129,600
U.S. currency seized from petitioner at the time of his arrest,
bank deposits maintained in petitioner's name, and several
automobiles.
On October 12, 1993, the U.S. District Court for the Eastern
District of Pennsylvania entered its judgment pursuant to said
guilty pleas. Petitioner was sentenced to prison for a term of 4
years. Upon his release from prison, he was to remain under
supervised release for varying periods of 3 to 5 years, which
were to run concurrently. The District Court assessed a $50 fine
against petitioner, in his criminal case, for each of the nine
counts to which he pleaded guilty.
Respondent determined petitioner's gross income to be
$72,090 and $68,980 from the distribution of illegal drugs for
the taxable years 1990 and 1991, respectively, the same amounts
as listed in the counts of the indictment charging income tax
evasion.
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