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petitioner, pursuant to a Rule 112 plea agreement, pleaded guilty
to one count of violating section 7203 for the 1987 tax year for
having willfully failed to disclose on his 1987 tax return that
he had interests in foreign bank accounts.
During the interview with special agents of the CID, when
asked about the existence of foreign bank accounts, petitioner
failed to disclose that he had bank accounts in Canada. When
specifically questioned about bank accounts in Canada, petitioner
stated that he thought he had an account with his father and that
his father's money was in the account. Petitioner stated that he
did not deal with this account as his father handled all of the
banking transactions for this account. During the years 1986
through 1989, petitioner did in fact have an account at the Royal
Bank of Canada which earned $255,216 in interest. During 1986
and 1987, petitioner also had an account at Canada Trust which
earned $836 in interest, and in 1989 had a joint account with his
father at the Bank of Montreal that earned $37 in interest.
During 1986, petitioner also had a London bank account and a
Swiss bank account on which he earned interest of $23,910 and
$10,415 respectively.
During the years 1985 through 1988, petitioner made numerous
cash deposits into bank accounts in Canada, seven of which
exceeded $10,000. Petitioner deposited over $230,000 in cash
2 Fed. R. Crim. P. 11.
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