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he pleaded guilty to, inter alia, the above-described first
charge and so much of the above-described second charge as
related only to the taxable year 1997.3 Mr. Clinkscale acknowl-
edged in Mr. Clinkscale’s plea agreement:
3. The defendant, Jantz S. Clinkscale, acknowl-
edges that the computation of additional adjusted gross
income set forth on Attachment A to this agreement is
accurate. Defendant acknowledges his liability for
additional tax, penalties, and interest based upon the
additional adjusted gross income set forth on Attach-
ment A.
Attachment A to Mr. Clinkscale’s plea agreement showed, inter
alia, additional adjusted gross income for the taxable years
1994, 1995, 1996, and 1997 of $83,821.91, $101,633.41,
$250,335.10, and $325,199.43, respectively.
Respondent issued a notice to Mr. Clinkscale and Ms.
3Mr. Clinkscale acknowledged in Mr. Clinkscale’s plea
agreement:
15. The defendant, Jantz S. Clinkscale, * * *
acknowledge[s] that no threats, promises, or
representations have been made, nor agreements reached,
other than those set forth in this agreement, to induce
the defendant, Jantz S. Clinkscale, to plead guilty.
This plea agreement sets forth the full and complete
terms and conditions of the agreement between
defendant, Jantz S. Clinkscale, and the United States.
* * * * * * *
17. The defendant, Jantz S. Clinkscale, as
indicated by his signature below, states that she [sic]
has read this plea agreement, has discussed it with his
attorney, has had all questions concerning the meaning
and impact of the plea agreement fully and
satisfactorily answered by his attorney, and
understands the terms of the plea agreement.
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