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making false statements with respect to his testimony at the
trial of Ryan's criminal case regarding the 1981 Roeder search
(that no money was illegally obtained), the 1983 Roeder search
(that nothing was illegally obtained and that money found there
was only $10,000), and the Carr search (that the money found
totaled $13,500).
Wilson, Grove, and Cattalo were found guilty of filing false
returns for the 1982 through 1984 taxable years under section
7206(1). Giongo was found guilty of the same charge for the 1983
and 1984 taxable years, but not guilty for the 1982 taxable year.
The District Court granted the Government's motion to mold
the jury's forfeiture verdict and for the entry of judgment of
forfeiture. United States v. Wilson, 742 F. Supp. 905 (E.D. Pa.
1989), affd. without published opinion 909 F.2d 1478 (3d Cir.
1990). As a result, Giongo, Wilson, Cattalo, and Grove were held
jointly and severally liable for $180,700, the amount the jury
determined the racketeering enterprise had derived from its
racketeering activity. The District Court ordered petitioners
and Hund to pay restitution of $5,000 to James Carr; in
accordance with statutory provisions, they were held jointly and
severally liable for that amount.
Federal Income Tax Returns
Petitioners each filed joint 1982 and 1983 Federal income
tax returns with their respective wives. On their respective
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