James E. Stafford - Page 7

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                                   Lester              Sooner    Sohio                
                    Sohio/Standard Goodson   Yurika    Federal   Federal              
          Year      Oil            Pontiac   Foods       Savings Credit Union         
          1982   $37,119.00    ---    ---     ---     ---                             
          1983       38,705.00    ---    ---   $54.00     ---                         
          1984       16,438.32 $1,618.93 $2,966.00     ---     ---                    
          1985      31,722.21      1,953.46  380.69    7.51      ---                  
          1986      51,898.12      ---       52.30     9.72      ---                  
          1987      52,599.72      ---       45.15     ---       $3                   
          1988       43,925.08    ---     38.40     ---     ---                       
          Petitioner's community share of the foregoing amounts is one-               
          half.  Petitioner received $6,201 in distributions from Sohio               
          Employees Investment Plan, of which his community share is                  
          $3,100.6  In 1985, petitioner sold 282.781 shares of Standard Oil           
          stock; his community share of the sale proceeds is $6,302.  In              
          1987, petitioner sold 8.089 shares of Standard Oil stock for                
          $621.12.  His community share of the sale proceeds is $311.                 
          Petitioner submitted Forms W-4 to his employer for 1984, 1985,              
          1986, 1987, and 1988 stating that he was exempt from Federal                
          withholding.  Petitioner did not file a Federal income tax return           
          for the tax years 1982, 1983, 1984, 1985, 1986, 1987, and 1988.             
          In August 1991, an indictment was filed against petitioner for              
          violating section 7201 for the years 1985, 1986, and 1987.7  In             



          6  The notice of deficiency specifies that petitioner                       
          received the Sohio Employees Investment Plan distributions in               
          1983.                                                                       
          7  Sec. 7201 provides:                                                      
                    Any person who willfully attempts in any manner to                
               evade or defeat any tax imposed by this title or the payment           
               thereof shall, in addition to other penalties provided by              
               law, be guilty of a felony and, upon conviction thereof,               
               shall be fined not more than $100,000 * * * or imprisoned              
               not more than 5 years, or both, together with the costs of             
               prosecution.                                                           



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