- 3 -
Background
Petitioner petitioned the Court on January 11, 1993, to
redetermine respondent's determination of deficiencies and
additions. On August 18, 1993, this case was calendared for
trial at the trial session commencing on January 24, 1994.
Beginning in November 1993, petitioner filed with the Court seven
separate motions for continuance. The Court granted the seventh
motion on July 18, 1996, and this case was calendared for trial
at the trial session commencing on April 14, 1997.
On January 29, 1997, respondent served petitioner with
requests for admission. The admissions requested were, in
pertinent part, as follows:
3. The petitioner filed an individual income tax
return, Form 1040, for each of the years 1984 and 1985.
He reported gross income of $46,825.00 for 1984 and
$73,762.00 for 1985, and reported tax liabilities of
$7,783.00 and $21,979.00 for 1984 and 1985,
respectively. * * *
4. The petitioner * * * was charged with multiple
counts of wire fraud under 18 U.S.C. �1343, mail fraud
under 18 U.S.C. �1343, interstate transportation of
property taken by fraud under 18 U.S.C. �2314,
conspiracy to defraud the United States under 18 U.S.C.
�371, and filing false income tax returns under 26
U.S.C. �7206(1) for the years 1984 and 1985 * * *.
* * * * * * *
6. The petitioner's objective [in conducting the
investment scheme] was to defraud the United States by
conducting the financial and banking activities of the
investment scheme in a manner which was not readily
traceable, by failing to maintain records of the
financial activities of the investment scheme, and by
failing to report to appropriate government agencies
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011