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Christensen was also found guilty of conspiracy, obstruction of
justice, and mail fraud. The corporation was found guilty of
conspiracy and aiding and assisting in the preparation of a false
corporate tax return for the fiscal year ending September 30,
1989.
On October 29, 1997, the U.S. District Court for the
District of Nevada (District Court) pronounced sentence on
petitioners. Petitioners were ordered to pay fines and make
restitution of civil tax liabilities to the Internal Revenue
Service for the tax years 1972 through 1993 (which years included
the years in issue before this Court). Specifically, the
District Court ordered the following criminal monetary penalties
and restitution of civil tax liability:
Lonnie C. Christensen M.J. Wood
Fine: $150,000 Fine: $1,000,000
Restitution: $3,794,773 (IRS)1 Restitution: $3,794,773 (IRS)
1This figure represents $1,707,573 in income tax
deficiencies and $2,087,200 in interest. The restitution figures
were expressed as a total amount jointly and severally due by the
individual and corporate defendants. The District Court did not
specify whether the amounts are attributable to a particular
defendant/taxpayer or taxable year.
The District Court further held that the defendants were jointly
and severally liable for restitution, but each defendant was
individually liable for the fine.
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