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for $27,500. Mr. Karcho requested that the purchaser pay the
$27,500 in the form of three cashier's checks for $9,500, $9,500,
and $8,500. During 1989, Mr. Karcho purchased 22 cashier's
checks, all in amounts less than $8,000, totaling $65,942.30.
The checks were payable to Mr. Karcho, and he purchased at least
19 of them with cash. During 1990, Mr. Karcho purchased 17
cashier's checks, all in amounts less than $7,000, totaling
$59,100.00. These checks were also payable to Mr. Karcho, and he
paid for them in cash. From approximately late-July to mid-
August 1990, Mr. Karcho purchased four cashier's checks: three
for $9,000 and one for $3,000. These checks he used for the
purchase of a 1986 Excaliber automobile. In addition, Mr. Karcho
made a downpayment on a residence with 13 cashier's checks, each
for an amount less than $3,000, that he purchased between
August 24, 1990, and January 16, 1991.
Criminal Investigation and Guilty Plea
The search and records seizure noted earlier resulted from a
criminal investigation of Mr. Karcho initiated in 1991. Mr.
Karcho was ultimately charged with one count of attempted income
tax evasion for the 1987 taxable year, in violation of section
7201, and one count of structuring transactions with intent to
evade currency reporting requirements, in violation of 31 U.S.C.
sec. 5324(3) (1994), in connection with the purchase of 13
cashier’s checks between August 24, 1990, and January 16, 1991.
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