- 3 - transactions in cash and did not maintain books and records memorializing the transactions. Petitioner received $38,528 and $34,976 in cash from cocaine sales during 1986 and 1987, respectively, but he failed to file Federal income tax returns for those years. Douglas Louzon (Louzon)2 was petitioner's longtime acquaintance and confidante. Louzon agreed to cooperate with Federal law enforcement officers in their investigation of petitioner's drug activities, including their investigation that centered around petitioner's conduct in 1986 and 1987. Louzon wore a secret wire and engaged petitioner in several conversations wherein petitioner openly discussed his drug sales, boasted about his income from the sales and about extravagant purchases, and expressed his dislike for the Internal Revenue Service and taxes. On October 10, 1990, petitioner was convicted of the following offenses in the United States District Court for the Western District of Michigan: (1) Conspiracy to possess with intent to distribute controlled substances; (2) monetary transaction in property derived from illegal activity; (3) laundering of monetary instruments; and (4) income tax evasion. Among the issues of fact determined in the criminal case were 2By 1987, Douglas Louzon had been convicted of several felonies including malicious destruction of property, carrying a concealed weapon, bank robbery, and possession of stolen property.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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