Maurice C. Wilson and Dorris E. Wilson - Page 5




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          and approximately $8,358 for those respective years.4  (We shall            
          refer to the proceeding in the U.S. District Court in which the             
          jury found Mr. Wilson guilty of, inter alia, income tax evasion             
          under section 7201 as Mr. Wilson’s criminal tax proceeding.)                
          Pursuant to the judgment imposed against Mr. Wilson in Mr.                  
          Wilson’s criminal tax proceeding, the U.S. District Court ordered           
          Mr. Wilson, inter alia, to pay restitution to the Internal                  
          Revenue Service (IRS) in the amount of $17,834.5  The amount of             
          restitution that the U.S. District Court ordered Mr. Wilson to              
          pay to the IRS was equal to the sum of the tax for each of the              
          taxable years 1993 and 1994 that the jury found Mr. Wilson                  
          underpaid for each such year.                                               
               On April 11, 2000, respondent issued to petitioners a notice           
          of deficiency (notice) for the taxable years 1993 and 1994.  In             
          that notice, respondent determined deficiencies in petitioners’             
          Federal income tax (tax), fraud penalties under section 6663, and           
          accuracy-related penalties under section 6662(a), as follows:               




               4Mr. Wilson was also found guilty of aiding and abetting               
          under 18 U.S.C. sec. 2 (2000).                                              
               5In a separate proceeding in the U.S. District Court, after            
          a trial by jury, the jury found Mr. Wilson guilty of mail fraud             
          under 18 U.S.C. sec. 1341 (2000) and aiding and abetting under 18           
          U.S.C. sec. 2.  Pursuant to the judgment imposed against Mr.                
          Wilson in that criminal proceeding, the U.S. District Court                 
          ordered Mr. Wilson, inter alia, to pay restitution to certain               
          insurance companies in the amount of $15,000.                               





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