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When he petitioned the Court, petitioner resided in Thousand
Oaks, California.
Background
Petitioner is an attorney. During 2002, the U.S. Attorney
filed in the U.S. District Court for the Northern District of
Florida, Gainesville Division (the District Court), a one-count
information charging petitioner with violating section 7201 by
willfully attempting to evade his 1996 income taxes and by filing
a fraudulent 1996 Federal income tax return.1 The information
charged that petitioner knowingly understated his 1996 taxable
income by $1,551,863.
In October 2002, petitioner entered into a plea agreement,
pleading guilty to the one-count information. In the plea
agreement, the parties agreed that by September 17, 2001,
defendant had paid restitution to the United States in the amount
of $1,590,000, and that this amount exceeded the “unreported fee”
set forth in the information and agreed statement of facts.2 In
connection with the plea agreement, on November 8, 2002, the
parties in the criminal case filed with the District Court an
agreed statement of facts, in which petitioner admitted that he
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Between August 1999 and September 2001, petitioner made
payments to the United States totaling $1,590,000.
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Last modified: May 25, 2011