- 3 - 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. * * *Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011