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Section references are to the Internal Revenue Code in
effect for the applicable years. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner was incarcerated in Florence, Colorado, when he
filed the petition in this case. He resided in California before
and after his incarceration.
Petitioner devised a scheme to obtain funds fraudulently
from certain individuals from 1991 to 1993. He falsely
represented to these individuals that members of his family
needed emergency medical care and that he could not pay their
medical expenses. He did not repay or ever intend to repay the
funds he received from those individuals. Petitioner received
$115,000 in 1991, $246,833 in 1992, and $48,800 in 1993 as a
result of this scheme. Petitioner did not file income tax
returns for 1991, 1992, or 1993.
B. Arcanum
Arcanum was established as an investment partnership on
February 4, 1981. Petitioner was Arcanum’s sole general partner
and one of its limited partners in the years in issue.
Petitioner signed Arcanum’s Form 1065, U.S. Partnership
Return of Income, for 1990. He checked a box on Arcanum’s return
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Last modified: May 25, 2011