- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011