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reporting, among other things, gross receipts from the dental
practice for the previous calendar year. Abingdon used this
information to calculate petitioner’s business license tax.
Petitioner timely filed applications reporting gross
receipts from the dental practice as follows:
Year Gross Receipts
1990 $117,342
1991 132,300
1992 174,072
1993 150,000
1994 190,000
On each application, petitioner affirmed under penalty of perjury
that the amount reported as gross receipts was “true and
correct”.
The Criminal Investigation
Petitioner initially failed to file Federal income tax
returns for the years 1983 through 1994. On June 15, 1996,
following an investigation by respondent’s Criminal Investigation
Division, petitioner executed a plea agreement wherein he agreed
to plead guilty to five counts of violating section 7203 for
willful failure to file Federal income tax returns--one count for
each of the subject years.2 On January 31, 1997, judgment was
entered by the United States District Court for the Western
District of Virginia, accepting petitioner’s guilty plea.
2 Pursuant to the terms of his plea agreement, petitioner
stipulated that “this plea agreement does not settle, compromise
or otherwise affect in any way any federal tax, interest, civil
penalty or other obligation for which I may now be, or in the
future become, liable under Title 26, United States Code.”
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