Joseph C. Minneman - Page 7

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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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