FINDINGS OF FACT AND CONCLUSIONS OF LAW
JED S. RAKOFF, U.S.D.J.
Having already received a windfall of nearly a half million dollars as a result of errors by the Internal Revenue Service, convicted tax felon Emilio Coppola seeks refund of an additional $ 24,059.75 on the basis of what he alleges were IRS mistakes. The cause was tried to the Court on May 13, 1996. While the evidence suggests that the IRS may be entitled to a gold medal for bungling, it fails to support Mr. Coppola's instant claim. More particularly, the Court hereby makes the following findings of fact and conclusions of law.
Findings of Fact
In 1986, Emilio Coppola pled guilty to one count of attempted tax evasion for 1981. Ex. 1.
Thereafter, on April 15, 1987, the IRS sent a statutory notice of deficiency, Ex. 2, to Mr. Coppola and his former wife, informing them that they owed past taxes of $ 1,397,908.44 and penalties of $ 698,954.22, broken down as follows:
Calendar Year Ended Deficiencies Fraud Penalty
December 31, 1979 $ 365,315.90 $ 182,657.95
December 31, 1980 $ 674,915.06 $ 337,457.53
December 31, 1981 $ 357,677.48 $ 178,838.74
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