Ames v. Commissioner
United States Tax Court
In 1985, P, an employee of the Central Intelligence Agency, began selling classified information to the Soviet Union. During 1985, P received a communication from a Soviet agent that $ 2 million had been set aside for P to draw upon. On Apr. 28, 1994, P pled guilty to conspiracy to commit espionage and tax conspiracy to defraud the U.S. Government. P was sentenced to life imprisonment on the espionage charge and to 27 months' imprisonment on the tax charge.
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In 1985, P, an employee of the Central Intelligence Agency, began selling classified information to the Soviet Union. During 1985, P received a communication from a Soviet agent that $ 2 million had been set aside for P to draw upon. On Apr. 28, 1994, P pled guilty to conspiracy to commit espionage and tax conspiracy to defraud the U.S. Government. P was sentenced to life imprisonment on the espionage charge and to 27 months' imprisonment on the tax charge. R determined that P failed to report as income amounts received and deposited in his bank accounts during 1989 through 1992. P contends…
1Opinion of the Court
Gerber, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax and section 6662(a)1 penalties as follows:
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The issues for our consideration are: (1) Whether petitioner constructively received income from illegal espionage activities during 1985, when it was allegedly promised and/or set aside for him, or when it was received and/or deposited in his bank accounts during the taxable years 1989, 1990, 1991, and 1992 in the amounts of $745,000, $65,000, $91,000,2 and $187,000, respectively; (2) whether petitioner is liable for the accuracy-related penalty for…
2Cases cited22 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- Kennedy v. Mendoza-MartinezSupreme Court of the United States · 1963
- Hudson v. United StatesSupreme Court of the United States · 1997
- Helvering v. MitchellSupreme Court of the United States · 1938
- United States v. WardSupreme Court of the United States · 1980
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3Cited by13 opinions
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- Schachter v. CommissionerUnited States Tax Court · 1999
- Aldrich H. Ames v. CommissionerUnited States Tax Court · 1999
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