- 11 - of conspiracy to commit fraud and numerous counts of mail fraud and for filing a false 1983 income tax return in violation of section 7206(1). The indictment, among other charges, alleged that petitioner, on or about June 29, 1984, filed a materially false 1983 income tax return by failing to report a substantial amount of income in addition to that stated on the income tax return. At the hearing under rule 11 of the Federal Rules of Criminal Procedure, petitioner admitted that he received and willfully failed to report a $21,000 management fee. On May 2, 1990, petitioner pled guilty to filing a materially false 1983 income tax return under section 7206(1), and he was sentenced to concurrent 3-year terms of imprisonment, along with the condition that he make restitution to the crime victims. OPINION This case is factually convoluted because of the maze of entities, principals, and transactions involved. The primary factual pattern involves petitioner's odyssey from being a successful insurance salesman to his involvement in a Ponzi scheme and, ultimately, to his incarceration. Initially, petitioner successfully sold insurance to farmers until he became reinvolved with his insurance business mentor, Roy. Roy, in turn, introduced Dean Cooper to petitioner. With the introduction of Roy and Cooper, petitioner's business activity became complicated. In addition to an S corporation through which petitioner operated his life insurance agency, Roy's insurance agency became affiliated with petitioner through and inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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