- 3 - 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:Page: Previous 1 2 3 4 5 6 7 8 Next
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