- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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