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whether he ever was married and what was the status of his
health. Additionally, he claimed not to remember what high
school he attended and when he graduated.
The special agents recommended that criminal proceedings be
instituted against petitioner. In an information filed on
March 2, 1994, the United States charged petitioner with one
count of willfully failing to file an income tax return in
violation of section 7203 for 1990. On June 23, 1994, petitioner
pleaded guilty to this charge. As part of his plea, petitioner
admitted that he did not timely file income tax returns for 1983
through 1992.
On September 24, 1993, petitioner filed Federal income tax
returns for 1983 through 1991. Petitioner reported tax
liabilities as follows: $7,403, $7,569, $6,890, $5,663, $3,949,
$3,881, $7,494, $7,377, $7,022 for 1983, 1984, 1985, 1986, 1987,
1988, 1989, 1990, and 1991, respectively.2 As of May 11, 1995,
petitioner paid these amounts and the interest associated with
these years.
OPINION
The addition to tax and penalty in the case of fraud is a
civil sanction provided primarily as a safeguard for the
2 Petitioner was married from 1983 through 1988. His tax
liabilities were reduced by $400, $1,616, $1,837, and $381 for
1983, 1984, 1985, and 1986, respectively, for amounts withheld by
his wife’s employer.
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