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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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