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of the apartment building and received a real estate commission
of $9,000 for the sale in 1993.
On October 15, 1993, WFIC purchased a 1993 Buick Riviera
(Buick). Mary’s 1991 Ford Probe was traded in and its value was
credited to the purchase of the Buick. The Buick was registered
in Mary’s name, and personalized license plates reading “PURRFCT”
were requested for the Buick. Petitioner did not report the
value of the Buick as income on his 1993 income tax return.
In 1994, petitioner represented on both a credit application
and a Uniform Residential Loan Application that he and Mary owned
Taxman, WFIC, and the Buick.
III. Petitioner’s Criminal Conviction
On September 11, 1997, a jury convicted petitioner of
intentionally filing false returns under section 7206(1) for
1990, 1991, 1992, and 1993 and of attempting to obstruct and
impede the administration of internal revenue laws from 1985
through 1997 in violation of section 7212(a). The U.S. District
Court for the District of North Dakota entered its judgment on
December 30, 1997, sentencing petitioner to 6 months’
imprisonment and ordering petitioner to pay the IRS $42,873.24 in
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