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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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