Schachter v. Commissioner
United States Tax Court
HELD: No credit is allowed against civil fraud additions to tax for a criminal fine imposed under sec. 7201, I.R.C., and 18 U.S.C. secs. 371, 3622, and 3623 (Supp. II, 1984).
1Opinion of the Court
SUPPLEMENTAL OPINION
Swift, Judge:
This matter is before us under Rule 155 on the parties’ disputed computations of the decision to be entered herein.
The issue for decision is whether petitioners should be allowed a credit against civil fraud additions to tax for a $250,000 criminal fine imposed on petitioner Martin Schachter (petitioner).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
On September 23, 1993, petitioner pleaded guilty under section…
2Cases cited10 opinions
- Kennedy v. Mendoza-MartinezSupreme Court of the United States · 1963
- Spies v. United StatesSupreme Court of the United States · 1943
- Hudson v. United StatesSupreme Court of the United States · 1997
- Ianniello v. Comm'rUnited States Tax Court · 1992
- Paul L. Thomas v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
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3Cited by2 opinions
- Martin and Barbara Schachter v. CommissionerUnited States Tax Court · 1999
- Schachter v. CommissionerUnited States Tax Court · 1999