Charles T. Wickersham and Sandra J. Wickersham - Page 9

                                         -9-                                          
          States v. Wickersham, Criminal No. 1:92-CR-98, in the U.S.                  
          District Court for the Eastern District of Texas.  Count VI of              
          the indictment charged Mr. Wickersham with willfully making and             
          subscribing a U.S. individual income tax return, verified under             
          penalties of perjury and filed with the Internal Revenue Service,           
          which he did not believe to be true and correct in every material           
          matter in that the income tax return failed to report a taxable             
          capital gain of $349,641 realized from the sale of the Peveto to            
          the OCPND, as he then and there well knew and believed that the             
          Peveto had not been involuntarily converted and that taxes were             
          due from any gain so realized from the sale in violation of                 
          section 7206(1).                                                            
               After a 6-day trial, the jury found Mr. Wickersham guilty on           
          count VI of the indictment and acquitted Mr. Wickersham and the             
          other defendants (Mr. Winfree and Mr. Frederick) on all other               
          counts.  In United States v. Wickersham, 29 F.3d 191 (5th Cir.              
          1994), the U.S. Court of Appeals for the Fifth Circuit affirmed             
          the conviction.                                                             
                                       OPINION                                        
          I.  Fraud                                                                   
               The penalty in the case of fraud is a civil sanction                   
          provided primarily as a safeguard for the protection of the                 
          revenue and to reimburse the Government for the heavy expense of            
          investigation and the loss resulting from a taxpayer's fraud.               






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