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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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