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commissions, tax preparation fees, loans, and real estate sales.
Throughout the years at issue, petitioner had two children,
Jamal and Joshua, who lived with petitioner and his wife. For
the taxable years 1982 and 1986, petitioner’s wife filed as
married filing separately and claimed Jamal and Joshua as
dependents.
In March 1993, petitioner pled guilty to (1) conspiring to
defraud the Government by impeding, impairing, obstructing, and
defeating the lawful functions of the Internal Revenue Service in
the ascertainment, computation, assessment, and collection of
revenue, in violation of 18 U.S.C. sec. 371, and (2) two counts
of bank fraud, in violation of 18 U.S.C. sec. 1014.6
Petitioner’s criminal conviction stemmed from his practice of
opening interest-bearing bank accounts under false names,
addresses, and Social Security numbers in an attempt to conceal
his financial activities.
Despite petitioner’s awareness of the requirements to file
Federal income tax returns and maintain books of account and
records of his business activities, petitioner consistently
failed to comply with either requirement. Consequently,
respondent subpoenaed petitioner’s bank records in order to
reconstruct petitioner’s income for all years at issue.
Respondent’s examination of petitioner’s bank records led
6Petitioner received a Federal prison sentence of 2 years
followed by 3 years of probation.
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