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The issues for decision are:1 (1) Whether a 1980 plea
agreement in Mobile, Alabama, between petitioner and the
Government precludes respondent from determining deficiencies in
taxes owed by petitioner. We hold it does not. (2) Whether
respondent's use of petitioner's Cayman Islands records was
improper because it violated grand jury secrecy rules. We hold
it was not. (3) Whether respondent's use of petitioner's Cayman
Islands records was improper because it violated a treaty between
the United Kingdom and the United States regarding Cayman Islands
information. We hold petitioner lacks standing to challenge any
purported violation of the treaty. (4) Whether respondent's use
of petitioner's Panamanian bank records was improper because it
violated Panamanian law or petitioner's Fourth Amendment rights.
We hold it was not. (5) Whether petitioner had unreported income
for the years at issue as determined by respondent. We hold he
did. (6) Whether petitioner is entitled to deductions for net
operating losses for the years in issue. We hold he is not. (7)
Whether petitioner is liable for additions to tax for fraud
1These consolidated cases essentially relate to unreported
income from narcotics trafficking and unreported interest earned
on that income. Docket No. 9376-88 relates to years when the
funds were located in the Cayman Islands, docket No. 7127-92
relates to years when the funds were located in Panama, and
docket No. 13113-96 relates to years when the funds were in the
custody of the District Court for the Southern District of
Florida before being transferred to the Internal Revenue Service
(IRS).
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