Eventually it all came crashing down, and he was criminally convicted for tax evasion, and sentenced to 24 months in prison and just over $1 million in restitution and fines.
Then came the civil tax case. That dealt with numbers that were, er, a bit larger.
I won't repeat the Tax Court opinion here. But I will make a few salient points.
His home and business were searched, and tax protestor literature was found. Tax documents were also found, at least one of which was filled out in all-zeroes tax-protestor fashion. He didn't defend himself against the deficiency with any TP or sovcit arguments, though; he went largely with the-government-ate-my-homework -- that he thought he didn't have to file (despite the fact that he did think that he'd made a rather sophisticated mark-to-market election, even though he apparently had no idea what "mark-to-market" actually meant), and that the government had stolen all the documents proving his innocence.
The Tax Court was rather unconvinced on this point. Here I will quote it:
And finally, there is the sheer amount of the deficiency. When I add up the deficiency and penalties for the eight months -- or, rather, when I tell Excel to do it, because I can't count that high -- it comes out to exactly $404,448,492.47. FOUR HUNDRED MILLION DOLLARS. And while the order ends with "Decision will be entered under Rule 155" rather than "Decision will be entered for respondent" -- which suggests that Dr. Reynoso must have accomplished something -- I don't see any point addressed in the opinion where Dr. Reynoso actually won. OUCH.Beneath all six of these issues is the common ground of Dr. Reynoso’s credibility. And we must find that there is not much there. Here are just some examples:
* Dr. Reynoso admitted during trial that he didn’t file his tax returns because he didn’t think he had to, but the substantial amount of tax-protester propaganda found in his home suggests otherwise.
* Dr. Reynoso claimed during trial that he didn’t bring his business records to trial because of their vastness, but Ms. Ryer, the criminal investigator, credibly testified that she never saw any records whatsoever during the search of Dr. Reynoso’s
residence. On brief Dr. Reynoso changed his story and now accuses the criminal investigators of taking and losing his
* Dr. Reynoso asserts that the misinformation on his 1099s and bank account records were mere typos. Believing this would require us to find that several insurance companies and large banks made multiple and similar typos rather than find that Dr. Reynoso submitted the incorrect information to those institutions.
* Dr. Reynoso insisted during trial that he created the T.F. Trust to protect himself, but could not offer up a single explanation as to how the trust would do so.