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1993. The referral was evaluated and accepted by CID for
investigation.
CID worked on the case from April or May of 1994 until it
recommended that petitioner be prosecuted for attempted income
tax evasion under section 7201 for both 1990 and 1991. The
recommendation was forwarded to the Department of Justice for
consideration on January 27, 1997. The Department of Justice
declined to prosecute the case and in late March or early April
of 1997 the case was returned to the revenue agent for civil
disposition.
The revenue agent issued his first report on May 13, 1997.
After receiving additional information from petitioner or his
representatives, a revised revenue agent's report was issued on
February 18, 1998.
Petitioner requested consideration of his case by the
Appeals Division of the IRS on April 20, 1998. The Appeals
Division settled with petitioner on income tax adjustments for
1990 and 1991. Petitioner and an Appeals Division representative
signed a Form 870-AD, Offer to Waive Restrictions on Assessment
and Collection of Tax Deficiency and to Accept Overassessment,
dated May 20, 1999. On the form, petitioner agreed to the
assessment of Federal income tax deficiencies of $9,485 for 1990
and $41,836 for 1991 as well as accuracy-related penalties under
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