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petitioner violated section 7206(4) in regard to his unpaid
income tax liabilities for 1977-82. On November 13, 1997,
pursuant to petitioner’s plea of guilty, the District Court
entered a judgment convicting petitioner of a violation of
section 7206(4) and sentenced petitioner to imprisonment. The
offense to which petitioner pleaded guilty occurred on August 9,
1990. In the plea agreement, petitioner admitted:
WALTER L. MEDLIN, in an attempt to avoid the
collection of a previously assessed income tax
liability for which levy was authorized under 26 U.S.C.
� 6331, placed three of his automobiles in a storage
facility, located on Michigan Avenue in Kissimmee,
Florida, in the Middle District of Florida, which
facility leased to an entity called Central Florida
Transportation Museum, Inc.
Specifically, the defendant MEDLIN, after
consenting to a United States Tax Court judgment
against him in the approximate amount of $400,000.00
for liabilities stemming from tax years 1977-1982,
misrepresented the nature and extent of his assets to
an IRS Revenue Officer. Further, after issuance of the
levy, defendant MEDLIN stored the automobiles in the
above-referenced storage facility and, when asked about
the case by and [sic] IRS Revenue Officer, stated that
he no longer owned the vehicles. MEDLIN knew this
statement to be false.
On November 14, 1997, respondent issued a notice of
deficiency to petitioner for 1985, 1986, 1987, and 1988. On
February 11, 1998, petitioner filed his petition.
Petitioner testified on his own behalf at trial. We find
that, generally, his testimony was self-serving, was not
credible, was at times inconsistent, and was at other times
confusing. Petitioner did not satisfactorily answer many of the
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