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issuing a notice of deficiency. That action was taken after
review of the case by the Examination Division and CID.
By letter dated February 27, 1992, petitioner was advised
that CID had recommended prosecution and had forwarded the case
to the District Counsel's Office of the Internal Revenue Service.
District Counsel reviewed the recommendation and forwarded the
case to the Tax Division, Department of Justice, on May 22, 1992.
On April 14, 1993, an indictment was returned by the Grand Jury
sitting in the U.S. District Court for the District of Oregon,
charging that petitioner and Ms. Taylor willfully attempted to
evade and defeat a large part of their income taxes for the
taxable years 1986 and 1987. On September 29, 1993, petitioner
entered a plea of guilty to the indictment pertaining to the
taxable year 1987 (Count 2). On November 12, 1993, petitioner
filed a motion to withdraw his plea. That motion was denied.
Petitioner was sentenced to 3 years' probation on December 8,
1993. Petitioner did not appeal from the sentence.
On June 6, 1994, petitioner filed a motion in the District
Court for new trial. That motion was denied on July 18, 1994.
On November 17, 1994, petitioner filed a motion to vacate under
28 U.S.C. section 2255 (1994). That motion was denied on January
17, 1995. Petitioner appealed to the U.S. Court of Appeals for
the Ninth Circuit, which affirmed the denial of relief by the
District Court. See United States v. Taylor, 70 F.3d 121 (9th
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