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tioner was married at the end of his taxable years 1990 and 1991,
petitioner claimed a filing status of single in his respective
returns for those years.
During respondent’s examinations of petitioner and of Duncan
& Associates with respect to their respective taxable years 1990
and 1991, petitioner fraudulently and corruptly obstructed and
impeded, and endeavored to obstruct and impede, the due adminis-
tration of the Code by knowingly creating and causing the cre-
ation of false and fraudulent documents for the purpose of
obstructing and impeding respondent’s examinations of petitioner
and of Duncan & Associates with respect to their respective
taxable years 1990 and 1991 and for the purpose of concealing
from respondent the falsity of petitioner’s return for each of
his taxable years 1990 and 1991 and of Duncan & Associates’
return for each such year.
On March 31, 1998, petitioner entered into a plea agreement
with the United States Attorney for the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in
violation of section 7212(a).3
3Sec. 7212(a) provides:
SEC. 7212. ATTEMPTS TO INTERFERE WITH
ADMINISTRATION OF INTERNAL REVENUE LAWS.
(a) Corrupt or Forcible Interference.–-Whoever
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