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guaranteed 30-percent annual return. In reality, there was no
such investment program.
In February 1995, in reliance on petitioner’s
misrepresentations, the Kieffers sent petitioner funds totaling
$9,500 to invest in the fictitious investment program.
Petitioner gambled these funds away. In February and May 1996,
the Kieffers sent petitioner additional funds totaling $65,000
funds to invest in the fictitious investment program.
Petitioner also gambled these funds away.
To further his fraudulent scheme and keep the Kieffers at
bay, petitioner gave the Kieffers various fabricated documents.
One of these documents, a doctored memorandum from the Federal
Employees’ Retirement System (FERS) dated March 14, 1995, falsely
described petitioner’s position as “Ass’t Executive Director of
Operations” at the Department of the Treasury. The document
purported to show that petitioner’s account in the Stopgap
Investments program had been opened for a total of $100,000, with
a guaranteed 30-percent rate of return. Petitioner also gave the
Kieffers another purported FERS memorandum, dated April 15, 1996,
which indicated that the guaranteed rate of interest had dropped
to 10 percent on an investment of $200,000. Finally, in 1998,
petitioner gave the Kieffers a version of petitioner’s own
statements of retirement benefits, which had been altered to show
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