- 4 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011