Nicholas M. Romer - Page 6




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         returns, under penalties of perjury, knowing that he had                     
         underreported gross receipts from his accounting firm and had                
         failed to report any gross receipts from his aviation activities.            
              On August 13, 1996, petitioner entered into a plea                      
         agreement, pleading guilty to one count of willfully failing to              
         supply information on his 1991 Federal income tax return pursuant            
         to section 7203.  The plea agreement states that petitioner                  
         “admits that the civil fraud penalty and interest applies to                 
         whatever additional tax he is deemed to owe after pursuing                   
         remaining civil remedies for tax years 1989-1991.”  Petitioner               
         was ultimately sentenced to 6 months’ imprisonment.                          
         Notice of Deficiency                                                         
              In the notice of deficiency, dated April 10, 1997,                      
         respondent determined that petitioner had failed to report gross             
         receipts from his accounting and aviation activities and other               
         sources in the following amounts:                                            
                             Romer &        Aviation        Other                     
                   Year      Co.            Activities      Income                    
                   1989      $144,607       $ 69,889        $1,966                    
                   1990      183,344        77,881          4,148                     
                   1991      369,337        102,313         978                       
              Respondent also determined that petitioner is subject to the            
         section 6663 civil fraud penalty and the section 6654(a) addition            
         to tax for failing to pay estimated taxes for each of the subject            
         years.                                                                       








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