Kenneth A. Weiner - Page 6

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                         m.  During the calendar years 1984 and                       
                    1985, the petitioner * * * used accounts                          
                    described above for the receipt and                               
                    disbursement of funds relating to the                             
                    investment scheme.                                                
                         n.  During the calendar years 1984 and                       
                    1985, the petitioner received approximately                       
                    $100,000 in currency from banking                                 
                    transactions relating to the investment                           
                    scheme * * *.                                                     
                         o.  During the calendar years 1984 and                       
                    1985, the petitioner used over $800,000 in                        
                    investment scheme funds to purchase cashiers                      
                    checks payable to himself * * *.                                  
               *    *       *      *         *       *      *                         
                    10.  On or about April 15, 1985, the petitioner                   
               filed his federal individual income tax return for the                 
               calendar year 1984, which income tax return was not                    
               true and correct in that he did not report his income                  
               from his involvement in the investment scheme.                         
                    11.  On or about October 17, 1986, the petitioner                 
               filed his federal individual income tax return for the                 
               calendar year 1985, which income tax return was not                    
               true and correct in that he did not report his income                  
               from his involvement in the investment scheme.                         
                    12.  In a jury verdict dated January 14, 1991, the                
               aforementioned Michigan district court found petitioner                
               guilty on all counts pertaining to him of the                          
               superseding indictment. * * *                                          
               *    *       *      *         *       *      *                         
                    16.  The petitioner omitted all of his income in                  
               the amounts of $1,100,411.00 received in 1984 and                      
               $1,905,387.00 received in 1985 from the investment                     
               scheme, from his 1984 and 1985 income tax returns,                     
               respectively, and filed these returns with the                         
               fraudulent intent to evade the tax due on that income.                 
                    17.  As a result of not reporting the                             
               aforementioned amounts of income, the petitioner                       





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