a $7,000 downpayment, and he had received an allowance of
$5,000 for trading in a 1979 Dodge Regis. He financed the
balance, $13,678.57, through a loan with Fidelity Bank &
Trust Co. payable over 4 years with monthly
installments of $367.31.
Mr. DiMichele was indicted by a Federal grand jury
on February 17, 1988, for conspiring to distribute metham-
phetamine, in violation of 21 U.S.C. sections 841 and 846,
(count 1), for distribution of methamphetamine, in viola-
tion of 21 U.S.C. section 841(a)(1) (counts 2 and 3), and
for possession of an unregistered firearm in violation of
section 5861(d) (count 4). Count 5 of the indictment
alleges that the currency, jewelry, bank accounts, and real
property owned by petitioners had been used to facilitate
the commission of the crimes charged in the indictment and
were subject to forfeiture under 21 U.S.C. section 853.
On March 16, 1988, the grand jury approved a super-
seding indictment that added three criminal tax violations
to the other criminal violations charged in the original
indictment. The new counts charged Mr. DiMichele with
willfully making and subscribing false income tax returns
for 1983 (count 6), 1984 (count 7), and 1985 (count 8), in
violation of section 7206(1).
Mr. DiMichele pled guilty to counts 1 and 8 of the
superseding indictment. As to count 1, Mr. DiMichele was
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