Sam F. and Ingrid D. Ford - Page 2

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          Code, as amended, and all Rule references are to the Tax Court              
          Rules of Practice and Procedure, with the exception of references           
          to rule 6(e), which are made to that provision as contained in              
          the Federal Rules of Criminal Procedure.                                    
               Some of the facts have been stipulated.  The parties'                  
          stipulation of facts and the accompanying exhibits are                      
          incorporated by this reference.  Petitioners, Sam F. Ford                   
          (hereinafter referred to as petitioner) and Ingrid Doorn Ford,              
          resided in Eugene, Oregon, when they filed their petition in this           
               Criminal Proceedings Against Petitioner                                
               On November 15, 1990, petitioner pled guilty, in the U.S.              
          District Court for the Southern District of New York, Case No. 90           
          Cr. 777 (WK), to one count of making a false statement to the               
          Securities and Exchange Commission, pursuant to 18 U.S.C. sec.              
          1001, and to one count of filing a false tax return for the                 
          taxable year 1986, pursuant to section 7206(1).  In his                     
          allocution incident to the guilty plea, petitioner stated:                  
               In this 1986 federal personal income tax return, I                     
               failed to include income in excess of $2.8 million                     
               dollars I had received from the sale of securities                     
               belonging to me which I had secreted in accounts in the                
               name of my son and others.  The income, however, was                   
               reported on my son's 1986 personal tax return and the                  
               tax was fully paid through him.                                        

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