- 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
Last modified: May 25, 2011