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petitioner that his 1992 return had been selected for
examination. On June 13 and July 28, 1994, a revenue agent met
with petitioner relating to the 1992 return.
On September 15, 1994, petitioner filed 1991, 1992, and 1993
amended returns; reported, on his Schedules C, increased taxable
income of $173,817, $191,595, and $63,628, respectively; and paid
the additional taxes and accrued interest due relating to these
years. On February 21, 1995, petitioner filed a 1990 amended
return, reported increased Schedule C taxable income of $134,859,
and paid the additional tax and accrued interest due relating to
that year. On April 8, 1996, petitioner filed a 1989 amended
return, reported increased Schedule C taxable income of $102,506,
and paid the additional tax and accrued interest due relating to
that year.
In 1996, petitioner was indicted for bank fraud, mail fraud,
money laundering, and, pursuant to section 7206(1),1 willfully
filing false tax returns. Petitioner was subsequently convicted
of filing false tax returns relating to 1989 through 1992 and
acquitted of bank fraud, mail fraud, and money laundering. The
conviction was affirmed on appeal.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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