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information and receive cash by means of signal sites and dead
drops. Petitioner continued his unlawful espionage activities
until his arrest in 1994.
During the years 1989, 1990, 1991, and 1992, petitioner and
his wife made deposits of cash received in connection with
petitioner’s unlawful espionage activities in the amounts of
$745,000, $65,000, $91,000, and $187,000, respectively. These
deposits did not represent transfers of funds from other accounts
or redeposits of currency previously withdrawn from other
accounts. Petitioner did not report on his income tax returns
for taxable years 1989, 1990, 1991, and 1992 any of the amounts
received from the KGB in connection with his illegal espionage
activities. Petitioner did not report on a Federal income tax
return (including his 1985 return) any amount of unlawful income
he received or that had been set aside for him.
On April 26, 1994, petitioner was indicted in the U.S.
District Court for the Eastern District of Virginia on charges of
conspiracy to commit espionage, under 18 U.S.C. sec. 794(c), and
conspiracy to defraud the U.S. Internal Revenue Service, under 18
U.S.C. sec. 371. On April 28, 1994, petitioner pled guilty to
both counts of the indictment. The indictment contained a
criminal forfeiture count pursuant to 18 U.S.C. sec. 794(d).
Petitioner was sentenced to life imprisonment on the espionage
charge and to 27 months’ imprisonment on the tax charge, the two
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