- 28 -
During the years 1980 through 1985, petitioners filed five
petitions with the Tax Court relating to taxable years ended 1972
through 1977 and to taxable years ended 1979 through 1981. In
the notices of deficiency for those years, respondent determined
deficiencies in tax totaling $2,088,901. Additions to tax for
fraud were determined in the notices of deficiency and
affirmatively pleaded in the answers to the petitions for taxable
years ended 1972 through 1975. Unreported income from an illegal
activity was not in issue for years ended 1972 through 1977 or
1979 through 1981. By agreement of the parties, decisions were
entered wherein deficiencies in tax for years ended 1974 through
1981, aggregating $286,126, were sustained, but additions to tax
for fraud were not sustained for any taxable year asserted. On
September 28, 1986, a Notice of Federal Tax Lien was filed in the
Circuit Court, Dade County, Miami, Florida, which reflected an
unpaid balance of assessment against petitioners for Federal
income taxes for the years ended 1974 through 1979, in the
aggregate amount of $818,184.16. Ms. Walters was aware of the
Tax Court litigation when she signed the tax returns for the
years in issue.
On December 29, 1986, Ms. Walters signed an IRS collection
information statement under penalty of perjury which did not list
as an investment an account at Prudential-Bache that was
maintained in the name "Justice For All Inc." Funds in that
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011