- 5 - interest payments in order to gain a tax deduction. Count Two of the plea agreement charged petitioner with willfully aiding and assisting in the false and fraudulent preparation and presentation of Mary Posnanski’s 1993 Federal income tax return, in violation of section 7206(2). Paragraph 7(e) of the plea agreement required petitioner “to pay the Internal Revenue Service those amounts owed for restitution on his personal restitution.” An addendum to the plea agreement set forth the following tax liabilities for petitioner and Lois Posnanski: Year Amount 1989 $3,749.29 1990 3,592.41 1991 3,194.08 1992 2,600.30 1993 2,007.16 Total 15,143.24 The addendum specifically stated that the tax liabilities were caused solely by petitioner. Petitioner transmitted a check dated February 12, 1996, payable to the Internal Revenue Service in the amount of $15,143.24, which was acknowledged as received by Steven M. Biskupic, the attorney for the United States in petitioner’s criminal proceeding. On February 23, 1996, petitioner entered his guilty plea and was convicted under 18 U.S.C. sec. 1001 for concealing material facts from the Internal Revenue Service and under section 7206(2) for aiding and abetting in the filing of a false Federal income tax return. In addition to prison time and other conditions,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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