Anderson v. Commissioner of Internal Revenue, No. 11-1704; Third Circuit; opinion by Roth, U.S.C.J.; filed September 7, 2012. Before Judges Sloviter, Roth and Pollak, District Judge, sitting by designation. On petition for review of an order of the U.S. Tax Court. DDS No. 35-8-xxxx [14 pp.]

Petitioner Walter Anderson was charged with federal tax evasion for tax years 1995 through 1999. The government alleged that he had fraudulently underpaid his taxes by $184 million, 99 percent of which stemmed from income generated by Gold & Appel Transfer S.A. (G&A), a British Virgin Islands corporation allegedly under his control. Pursuant to a plea agreement, Anderson pleaded guilty to tax evasion charges for 1998 and 1999; the charges for 1995, 1996 and 1997 were dismissed.