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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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