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Petitioner filed a motion to vacate his criminal conviction
pursuant to 28 U.S.C. sec. 2255 (1994). The District Court
denied petitioner's motion on March 31, 1994. Petitioner
appealed the District Court's judgment to the Court of Appeals
for the Fourth Circuit. In an unpublished per curiam opinion
filed April 21, 1995, the Court of Appeals for the Fourth Circuit
affirmed the judgment of the District Court. On June 14, 1995,
the Court of Appeals entered its judgment affirming the District
Court.
For the taxable year 1985, respondent determined petitioner
received $4,120 of unreported income.2 Respondent determined a
deficiency in, and additions to, petitioner's Federal income tax
for the taxable year 1985 as follows:
Additions to Tax
Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2)
$1,577 $5,017 50 percent of the interest
due on $1,577
Petitioner resided in St. Michaels, Maryland, at the time he
petitioned this Court to redetermine respondent's determination
of a deficiency in his income tax and additions to tax as set
forth above. Respondent's answer and amended answer included
2 Respondent's motion is for partial summary judgment
with respect to whether petitioner is estopped to dispute that
there is an underpayment in his income tax for 1985 and that part
of the underpayment is due to civil fraud pursuant to sec.
6653(b). The amount of the underlying deficiency for 1985
remains to be adjudicated.
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