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interest in the amount of $529,298.71. The $5,132,074.88
received by the IRS during 1992 was applied to petitioner's
unpaid tax assessments.
Petitioner was sent a form "Combined 1099/1098 Tax
Statement" by NationsBank. It was addressed "Jerry Lee Harvey,
5231 N.W. 84th Avenue, Fort Lauderdale, FL 33351-4903." This
form states that petitioner earned interest in the amount of
$529,298.71 during 1992. Petitioner did not report this income.
OPINION
Issue 1. Petitioner's 1980 Plea Agreement
Petitioner asserts that his 1980 plea agreement in Mobile,
Alabama, bars the Government from collecting any taxes on the
Cayman Islands funds he had accumulated before the agreement.
Petitioner's argument is that his 1980 agreement gave him
prospective civil tax immunity from the interest earned on the
fruits of his drug-trafficking career. Petitioner has advanced
this argument unsuccessfully in the past.
To summarize, petitioner accumulated substantial amounts of
money as a drug trafficker. He deposited this money in
clandestine accounts in the Cayman Islands, where it earned a
considerable amount of interest. Petitioner intentionally did
not report this interest income on any Federal income tax return.
When petitioner was arrested in Mobile, Alabama, he entered into
a plea agreement in which he cooperated with the Government.
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