Richard A. Wilson - Page 3




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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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