- 4 - 18. The petitioner understated his taxable income on his income tax returns for the taxable years 1986, 1987, 1988 and 1989, in the amounts of $209,192.00, $145,966.00, $181,965.00 and $231,448.00, respectively. 20. The petitioner understated his income tax liabilities on his income tax returns for the taxable years 1986, 1987, 1988 and 1989, in the amounts of $104,596.00, $56,197.00, $50,951.00 and $64,805.00, respectively. 21. A part of each deficiency in income tax for taxable years 1986, 1987, 1988 and 1989, is due to fraud with intent to evade taxes. 22. Richard P. Console, the petitioner herein, is the same person who was the defendant in the criminal case of United States of America v. Richard P. Console (District of New Jersey), Case Number 91-42(nhp). 23. The respondent herein is a party in privity with the United States of America, the prosecuting party in the aforesaid criminal case in which the petitioner herein was the defendant. 24. The indictment filed on January 10, 1991, in said criminal case sets forth the following charge against the defendant, the petitioner herein: THE GRAND JURY CHARGES: COUNT ONE On or about September 8, 1987, in the District of New Jersey and elsewhere. RICHARD P. CONSOLE, Esq., the defendant, unlawfully, wilfully and knowingly did attempt to evade and defeat a large part of the income tax due and owing by himself to the United States of America for the calendar year 1986, by preparing and causing to be prepared, signing and causing to be signed and filing and causing to be filed with the Internal Revenue Service, a false and fraudulent 1986 United States Individual Income Tax Return on behalf of himself, wherein it was stated that his taxable income for the said calendar year was $145,565.00 and that thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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