- 3 - Petitioner herein was the defendant in the criminal case of United States v. Frey, docket No. 95CR00035-J, which was tried in the U.S. District Court for the Western District of Kentucky. Petitioner was indicted on April 5, 1995, with respect to the criminal matter. The indictment charged that petitioner, who was employed as the Director of Corrections for the Jefferson County Department of Corrections, received bribes in exchange for assisting a corporation in obtaining certain contracts. In addition, the indictment charged that petitioner knowingly and willfully attempted to evade Federal income tax for 1990, 1991, 1992, and 1993 by filing false and fraudulent joint returns in violation of section 7201. Petitioner was charged with underreporting income, on behalf of himself and his spouse, in the amounts of $44,000, $48,000, $44,000, and $52,989 for tax years 1990, 1991, 1992, and 1993, respectively. It was petitioner's position that these amounts were received by him during the years in issue as nontaxable loans. Petitioner was found guilty of conspiracy to commit extortion, mail fraud, money laundering, and tax evasion. Respondent asserts that petitioner's conviction of tax evasion under section 7201 collaterally estops him from rebutting the determination that he is liable for civil fraud penalties under section 6663 for the same years. Respondent further maintains that the deficiencies in income tax and the penaltiesPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011