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It is too heavy for you alone]2
On March 12, 1995, the DEA used the notes along with other
evidence to show probable cause for a warrant to search the box
at Univault. The search revealed the attache case filled with
$339,860 of cash, which the DEA seized. The DEA also seized
Univault's records of the rental payments made on the box and the
lease agreement between Robert Morrison and Univault.
After his arrest, petitioner agreed to plead guilty to one
count of violating 42 U.S.C. 408(g), misrepresentation of a
Social Security account number, and one count of violating 21
U.S.C. secs. 841 and 846, conspiring to distribute cocaine. The
charges against Nelson were dismissed. Petitioner was
incarcerated in a Federal prison in Lompoc, California, for 2
years and 8 months.
OPINION
Issue 1. Whether Petitioner Had Unreported Income in 1987 and
1988
Respondent determined that petitioner had unreported income
of $5,965,240 and $339,860, and deficiencies of $2,294,259 and
$102,800 in 1987 and 1988, respectively. By an amendment to
answer, respondent increased the deficiency for 1988 to $110,500,
to account for the cash seized from the Cadillac. Petitioner
asserts that he had no income during the years at issue, or, in
the alternative, if this Court finds that he did have income,
that it was no more than $48,900 in 1987 and $55,600 in 1988.
2This postscript was crossed out.
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