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would not claim an interest of any kind in the seized funds. The
plea agreement concludes with statements acknowledging that
petitioner had adequate time to discuss the case with his
attorneys, his attorneys provided him all the legal advice he
requested, he made the plea voluntarily, no one coerced or
threatened him to enter into the plea agreement, and his
attorneys explained all the rights he had as a criminal defendant
and all the terms of the plea agreement.
Petitioner was represented during his criminal trial by two
experienced criminal defense attorneys, Penelope Cooper and Ted
Cassman. Petitioner’s attorneys signed the plea agreement and
stated that petitioner understood all the terms of the plea
agreement, and that petitioner’s decision to plead guilty was
knowing and voluntary.
On November 14, 2000, petitioner signed a Form 4549, Income
Tax Examination Changes, for 1995. Petitioner agreed to a
$440,042 deficiency in tax and a $330,031.50 fraud penalty
pursuant to section 6663 for 1995. The Form 4549 listed
$367,289.70 in interest due as of November 23, 2000. Above the
signature block Form 4549 states:
Consent to Assessment and Collection--I do not wish to
exercise my appeal rights with the Internal Revenue
Service or to contest in the United States Tax Court
the findings in this report. Therefore, I give my
consent to the immediate assessment and collection of
any increase in tax and penalties, and accept any
decrease in tax and penalties shown above, plus
additional interest as provided by law. * * *
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