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income tax deficiency of $486,399 and a section 6662(b)(2)1
penalty of $97,280 for the Christensens' 1990 taxable year. A
separate statutory notice of deficiency was mailed to petitioner
M.J. Wood Associates, Inc. (M.J. Wood), on April 14, 1994,
determining an income tax deficiency of $94,640 and a section
6662(b)(2) penalty of $18,928 for the fiscal year ending
September 30, 1990. Petitions were timely filed in both cases.
Thereafter, petitioners became defendants in the criminal
case captioned United States v. Lonnie C. Christensen Et Al.,
docket No. COMMISSIONER-S-95-74-LDG (LRL) (D. Nev. 1997), which
was commenced on April 7, 1997. By the parties' choice, the
civil income tax cases pending before this Court were generally
inactive during pendency of the criminal proceedings.
Petitioners' criminal indictments were issued on or about
January 17, 1996. Petitioners were charged with conspiracy,
beginning in 1972 and continuing through February 1994, to
defraud the United States for the purpose of obstructing the
assessment and collection of individual and corporate income
taxes. In addition, Mr. Christensen was charged with willfully
filing false individual income tax returns for 1988, 1989, and
1990 under section 7206(1), of which he was found guilty. Mr.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years under
consideration, and all Rule references are to this Court's Rules
of Practice and Procedure.
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