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the following methods by which Measurex could delay the IRS
investigation of petitioner: "One way to 'delay' would be to
write Regan asking him for a schedule of payment fees for the
documents. A second way would be to submit copies of only the
front of the checks in the first submission."
On February 11 and 12, 1982, respondent received revised
Forms 1040 relating, respectively, to petitioner's 1979 and 1980
tax years. Petitioner, on the 1979 form, reported gross income
of $83,082 and a tax liability of $41,210. Petitioner, on the
1980 form, reported wages of $182,352. Petitioner crossed out
the declarations that these forms were being submitted under
penalties of perjury.
On January 21, 1983, respondent received a Form 1040X
relating to petitioner's 1980 tax year. Petitioner reported a
tax liability of $178,191 and signed the form under penalties of
perjury, but he failed to report the $5,845 vacation allowance
and the $328,455.37 long-term capital gain.
On April 9, 1986, a criminal information was filed in the
U.S. District Court for the Western District of Washington
charging petitioner, pursuant to section 7203, with willful
failure to file 1979 and 1980 Federal income tax returns.
Thereafter, petitioner left the country. On July 22, 1987, a
U.S. Magistrate issued a bench warrant for petitioner's arrest.
On April 8, 1991, officers from the U.S. Customs Service arrested
petitioner at Logan International Airport in Boston,
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