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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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