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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