- 2 -
(tax):
Fraud
Additions to Tax Penalty
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6663(a)
1
1987 $24,505 $18,379 -- --
1988 $11,450 -- -- $8,588 --
1989 $13,257 -- -- -- $9,943
1 50% of interest due on $24,505
The only issue remaining for decision2 is whether petitioner
is entitled to a credit for the $65,000 that he forfeited to the
United States. We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time petitioner filed the petition in this case, he
resided in Rochester, Minnesota.
On a date not disclosed by the record, the United States
Attorney for the Northern District of Illinois (U.S. Attorney)
instituted a criminal proceeding against petitioner (petitioner’s
criminal proceeding) and charged him in a document entitled
“SUPERSEDING INFORMATION” (superseding information) with four
counts (four counts) alleging violations of 18 U.S.C. sec. 666
(bribery), 18 U.S.C. sec. 844(i) (arson), 18 U.S.C. sec. 1344
(bank fraud) and 26 U.S.C. sec. 7201 (income tax evasion). The
U.S. Attorney further charged petitioner in the superseding
2Petitioner concedes all the determinations in the notice of
deficiency.
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