Richard A. Wilson v. Commissioner

118 T.C. No. 33

UNITED STATES TAX COURT RICHARD A. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13703-01. Filed June 12, 2002. In conjunction with a criminal prosecution for tax evasion, P executed a Plea Agreement in which he agreed to file delinquent Federal income tax returns and report specific amounts of income. After assessing the tax liabilities reported on the delinquent returns, R sent P a notice of deficiency determining only additions to tax for fraudulent failure to file and failure to pay estimated tax under secs. 6651(f) and 6654(a), I.R.C.,…