Charles Y. and Jin Y. Choi - Page 9




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          under section 72013 for 1992.  In the process of his plea                   
          agreement petitioner averred that:  (1) He and his spouse had a             
          substantial income tax due and owing to the United States for the           
          year 1992; (2) he evaded tax by filing and causing to be filed              
          with the Internal Revenue Service a false and fraudulent Form               
          1040, U.S. Individual Income Tax Return, for the calendar year              
          1992 in which he substantially underreported gross receipts; (3)            
          he acted willfully, with intent to defraud the Government of the            
          tax on the additional unreported income.  Petitioner was                    
          sentenced to 12 months in prison and required to pay a $20,000              
          fine.                                                                       
               Petitioner’s father obtained a favorable judgment from a               
          civil court in Korea on May 17, 1991, which was appealed, and the           
          appeal was dismissed on May 18, 1993.  The payment of the                   
          judgment was not available to petitioner’s father and mother                
          until some time during 1993 or 1994.                                        






               3 Sec. 7201 provides:                                                  
                    Any person who willfully attempts in any manner to                
               evade or defeat any tax imposed by this title or the                   
               payment thereof shall, in addition to other penalties                  
               provided by law, be guilty of a felony and, upon                       
               conviction thereof, shall be fined not more than                       
               $100,000 ($500,000 in the case of a corporation), or                   
               imprisoned not more than 5 years, or both, together                    
               with the cost of prosecution.                                          





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