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during each of those years.
During 1994, Mr. Wilson received an additional $98,934 from
Industrial Medical in the form of checks written on a bank
account other than its business operating bank account. Those
checks specifically identified the purpose of such checks as loan
repayments, and the proceeds of those checks represented loan
repayments.
Petitioners jointly filed Form 1040, U.S. Individual Income
Tax Return, for 1993 (1993 joint return). In their 1993 joint
return, petitioners did not report the $44,000 in compensation
and the $7,315 in compensation that Industrial Medical paid
during 1993 to Mr. Wilson and Ms. Wilson, respectively.
Petitioners jointly filed Form 1040, U.S. Individual Income
Tax Return, for 1994 (1994 joint return). In their 1994 joint
return, petitioners did not report the $30,621 in compensation
and the $15,030 in compensation that Industrial Medical paid
during 1994 to Mr. Wilson and to Ms. Wilson, respectively.
After a trial by jury in the United States District Court
for the District of Maryland (U.S. District Court), the jury
found Mr. Wilson guilty, inter alia, of income tax evasion under
section 7201 for the taxable years 1993 and 1994 for
underreporting taxable income of approximately $50,969 and
approximately $49,253 and underpaying tax of approximately $9,476
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