- 19 - 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 thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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