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In 1987 and 1989, Finley, Romeyn, and petitioner were each
convicted of related crimes involving dishonesty and false
statements in the Federal District Court for the District of
Rhode Island. Finley and Romeyn each pled guilty in 1987 to two
counts of making false statements on documents submitted to the
Federally insured Old Colony Co-Operative Bank requesting
construction loan advances, in violation of 18 U.S.C.
section 1014. Romeyn also pled guilty in 1987 to one count of
making material false statements on the Landing 1982 Federal
income tax return in violation of section 7206(1); these material
false statements consisted, in part, of falsely deducting
payments made to R&S as business expenses. On May 19, 1989,
petitioner was convicted of willful attempted evasion of his 1981
and 1982 income tax liabilities under section 7201. This
conviction was affirmed by the Court of Appeals for the First
Circuit. See United States v. Fitzpatrick, 892 F.2d 162 (1st
Cir. 1989). Petitioner was also convicted of two counts of
conspiracy to travel, and use of the mails and interstate
commerce between Rhode Island, New York, and the Republic of
Panama to facilitate bribery and the distribution of the proceeds
of bribery in violation of 18 U.S.C. sections 1952 and 2.
OPINION
A. Unreported Income
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