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371 for conspiracy to defraud the United States by impeding the
collection of income tax by the Internal Revenue Service (IRS).
In June 1997, following a jury trial, petitioner was found
guilty, and judgment was entered by the U.S. District Court for
the Central District of Illinois. Petitioner was sentenced to 30
months’ imprisonment and 3 years of supervised release and
ordered to pay $25,000 in restitution to the IRS.
Petitioner appealed his conviction, but it was affirmed by
the Court of Appeals. United States v. Minneman, 143 F.3d 274
(7th Cir. 1998). Petitioner’s subsequent motion to vacate his
sentence pursuant to 28 U.S.C. sec. 2255 was denied by the
District Court in August 1998, and the Court of Appeals declined
to issue a certificate of appealability. Appeals filed by
petitioner from other adverse orders of the District Court were
equally unsuccessful on appeal. United States v. Minneman, 87
AFTR 2d 2001-1920 (7th Cir. 2001).3
E. The Notice of Deficiency
In May 1999, after the completion of an examination that had
commenced several years earlier, respondent issued a notice of
deficiency to petitioner. In the notice, respondent determined
deficiencies in petitioner’s Federal income taxes for 1989, 1990,
3 At the time of trial, April 2001, petitioner had been
disbarred from the practice of law. Whether petitioner was
disbarred because of his felony conviction for conspiracy or for
some other reason(s) is not disclosed in the record.
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