Donald R. Cooley and Cathy A. Cooley - Page 8

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          acknowledged that for his 1990 tax year, he attempted to evade or           
          defeat a tax, that additional taxes were due and owing, and that            
          his actions were willful.  In section A-7, as part of the plea              
          agreement, the Department of Justice agreed not to charge                   
          petitioner with any other Federal criminal offenses relating to             
          his 1988 through 1994 taxable years.  Moreover, in section A-9 of           
          the plea agreement, petitioner agreed to:                                   
               pay all taxes, interest and penalties found to be                      
               lawfully owed and due to the Internal Revenue Service                  
               for the years 1987 through and including 1995, and to                  
               cooperate with, and provide to, the Internal Revenue                   
               Service, any documentation necessary for a correct                     
               computation of all taxes due and owing for those years,                
               and further agrees that the Court may make this term a                 
               condition of any sentence of probation or supervised                   
               release.                                                               
               Section B-7 of the plea agreement provided:                            
               The defendant further acknowledges defendant’s                         
               understanding of the nature of the offense or offenses                 
               to which defendant is pleading guilty, and the elements                
               thereof, including the penalties provided by law, and                  
               defendant’s complete satisfaction with the                             
               representation and advice received from defendant’s                    
               undersigned counsel.                                                   
               Section B-8 of the plea agreement provided:                            
               Defendant is pleading guilty because defendant is in                   
               fact guilty.  The defendant certifies that defendant                   
               does hereby admit that the facts set forth below are                   
               true, and were this case to go to trial, the United                    
               States would be able to prove those facts beyond a                     
               reasonable doubt.                                                      
               On April 30, 1997, Judge Fernando J. Gaitan, Jr., of the               
          United States District Court, Western District of Missouri,                 
          entered a judgment against petitioner pursuant to section 7201,             





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