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Ronald Freetly also purchased for petitioner, using
petitioner’s funds, the following assets:
01/18/88 Vermeer used tractor $3,500
02/02/88 1966 Ford pickup 600
02/18/88 Tractor equipment 830
On August 12, 1987, petitioner’s sister purchased a house
trailer for petitioner for $20,884, making a downpayment of
$2,089 and financing the balance. During 1988 and 1989, she made
principal and interest payments on the property totaling $5,964,
in addition to utility payments for telephone, electricity, and
gas for the property. Petitioner lived in the house trailer
throughout 1988 and 1989. He reimbursed his sister for all the
payments she made on the house trailer, sometimes giving her cash
and sometimes endorsing over to her checks that he received from
other sources.
Petitioner did not file Federal income tax returns for
taxable years 1988 and 1989.
The Criminal Proceeding
On April 14, 1995, a Federal grand jury indicted petitioner
with three counts of violating section 7201, attempting to evade
or defeat tax, for taxable years 1988, 1989, and 1990, and three
counts of violating section 7203, willful failure to file a
Federal income tax return, supply information or pay tax, for
taxable years 1988, 1989, and 1990. On June 18, 1996, petitioner
pleaded guilty to violating section 7201 for taxable year 1989.
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