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Court.” As explained below, we shall grant respondent’s motion
to dismiss.
Background
On July 2, 1999, petitioner executed a Plea Agreement
pursuant to rule 11 of the Federal Rules of Criminal Procedure.
In the Plea Agreement, petitioner agreed, inter alia, to file
with the Internal Revenue Service delinquent Federal income tax
returns for 1991, 1992, 1993, and 1994. In this regard, the Plea
Agreement states in pertinent part:
The defendant will file with the Internal Revenue
Service delinquent individual income tax returns, Forms
1040, for the years 1991, 1992, 1993, and 1994,
reporting, as income to him, diverted corporate
receipts and dividend income totaling $328,915,
$176,376, $222,472, and $251,839, respectively.
On March 22, 2000, petitioner filed U.S. Individual Income
Tax Returns, Forms 1040, for 1991, 1992, 1993, and 1994 in
compliance with the Plea Agreement. Petitioner reported tax
liabilities of $95,778, $48,262, $72,760, and $84,247 for the
years 1991, 1992, 1993, and 1994, respectively.
On September 13, 2001, respondent issued to petitioner a
notice of deficiency. In the notice, respondent determined that
although petitioner is not liable for any deficiencies in income
taxes, he is liable for additions to tax under section 6651(f)
(fraudulent failure to file) and section 6654 (failure to pay
estimated tax) for the years and in the amounts as follows:
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