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under scrutiny. She was contacted by the Criminal Investigation
Division (CID) of the IRS about her CNC income and investments.
As a result of the contact by CID, petitioner on January 17,
1997, filed amended joint Federal income tax returns for 1991 and
1992, and amended individual tax returns for 1993 and 1994. The
amended returns reported distributions received from CNC in the
tax years for which they were filed.
On September 22, 1997, petitioner pleaded guilty to one
count of attempted income tax evasion for 1993 in violation of
section 7201. On January 5, 1998, she was ordered imprisoned and
fined as her sentence for the guilty plea to attempted evasion of
income tax. On August 10, 1999, petitioner signed Forms 870,
Waiver of Restrictions on Assessment and Collection of Deficiency
in Tax and Acceptance of Overassessment, agreeing to the
assessment of deficiencies in tax for 1991, 1992, 1993, and 1994,
as well as the fraud penalty under section 6663 for 1993.
Further, petitioner and the Commissioner's delegate signed a Form
906-c, Closing Agreement On Final Determination Covering Specific
Matters, agreeing to the amounts of taxable income received by
petitioner from CNC for the years 1991 through 1995.
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