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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.
Background
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
case.
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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