- 5 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011