John R. Toney - Page 4

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          of tax evasion in violation of section 7201.  Petitioner                    
          admitted:                                                                   
               On or about November 2, 1990, within the Western                       
               District of Washington, [he] * * * submitted to the                    
               Internal Revenue Service, a 1986 U.S. Individual Income                
               Tax Return, for which he claimed he was not a taxpayer                 
               within the meaning of federal tax laws and therefore                   
               not subject to payment of taxes, as required by law.                   
               [Petitioner]’s tax due and owing for the calendar year                 
               1986 was $14,611, which he did not pay.  As evidenced                  
               by cashing out income checks, not using business bank                  
               accounts, paying expenses with cash or money orders,                   
               attempting to place assets in the name of the Basic                    
               Bible Church, and destroying business records,                         
               [petitioner] acknowledges that he attempted to evade                   
               federal taxes due and owing for the tax year 1986, the                 
               likely effect of which was to mislead or conceal.                      
               On July 19, 1996, the U.S. District Court for the Western              
          District of Washington (U.S. District Court) accepted                       
          petitioner’s plea and entered judgment against petitioner.  The             
          U.S. District Court directed petitioner to pay restitution to               
          respondent in the amount of $14,611.  The U.S. District Court               
          held a hearing for petitioner, pursuant to rule 11 of the Federal           
          Rules of Criminal Procedure, before it accepted petitioner’s                
          plea.                                                                       
               Petitioner did not appeal the judgment of the U.S. District            
          Court.                                                                      
               On May 24, 2001, respondent issued a notice of deficiency.             
          Respondent determined a deficiency of $14,611, and additions to             
          tax of $10,958 pursuant to section 6653(b)(1)(A), 50 percent of             








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