Aldrich H. Ames - Page 1

                                   112 T.C. No. 20                                    

                               UNITED STATES TAX COURT                                

                           ALDRICH H. AMES, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14031-96.                     Filed May 28, 1999.           

                    In 1985, P, an employee of the Central                            
               Intelligence Agency, began selling classified                          
               information to the Soviet Union.  During 1985, P                       
               received a communication from a Soviet agent that $2                   
               million had been set aside for P to draw upon.  On                     
               Apr. 28, 1994, P pled guilty to conspiracy to commit                   
               espionage and tax conspiracy to defraud the U.S.                       
               Government.  P was sentenced to life imprisonment on                   
               the espionage charge and to 27 months’ imprisonment on                 
               the tax charge.                                                        
                    R determined that P failed to report as income                    
               amounts received and deposited in his bank accounts                    
               during 1989 through 1992.  P contends that he                          
               constructively received the majority of the illicit                    
               espionage income in 1985, the year he was informed that                
               $2 million had been set aside for him.  P also contends                
               that he is protected by the Double Jeopardy Clause of                  
               the Fifth Amendment to the U.S. Constitution from the                  
               assessment of any tax or civil penalties based upon his                
               illegal espionage income.                                              

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