Lawrence J. Polidori - Page 9

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          violation of section 7206(1).  Count one of the plea agreement              
          reads as follows:                                                           
                    That on or about April 15, 1986, in the State and                 
               Eastern District of Wisconsin,                                         
                          [Petitioner]                                                
               the defendant herein, who, during the calendar year                    
               1985, was a resident of Franksville, Wisconsin, did                    
               willfully make and subscribe a joint federal income tax                
               return (Form 1040) on behalf of himself and his then-                  
               wife Fern Polidori, for the calendar year 1985, which                  
               return was verified by a written declaration that it                   
               was made under the penalties of perjury, and was filed                 
               with the Internal Revenue Service, which return the                    
               defendant did not believe to be true and correct as to                 
               every material matter in the following respects:                       
                    (1)   The defendant falsely indicated on the                      
                    return that he did not have any financial                         
                    accounts in foreign countries during 1985,                        
                    whereas, in fact, as the defendant well knew,                     
                    he and his then-wife had an account at the                        
                    Swiss Bank Corporation (Overseas) Ltd.,                           
                    located in Nassau, Bahamas, in which, at                          
                    various times during 1985, he had deposits                        
                    exceeding $500,000;                                               
                    (2)   The defendant falsely indicated on the                      
                    return that he and his then-wife had total                        
                    income during the year 1985 of only                               
                    $55,367.43, whereas, as the defendant well                        
                    knew, he and his wife had total income                            
                    substantially in excess of the amount stated                      
                    because the defendant and his wife had earned                     
                    substantial additional income during 1985 on                      
                    their deposits at the Swiss Bank Corporation                      
                    (Overseas) Ltd., Nassau, Bahamas, which                           
                    income was not reported on the return; and                        
                    (3)   The defendant falsely indicated on the                      
                    return that he and his then-wife had interest                     
                    income during 1985 of only $450.76, whereas,                      
                    as the defendant well knew, he and his wife                       
                    had interest income in excess of the amount                       
                    stated.                                                           





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