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in relation to his 1989 tax year. As part of his plea agreement,
petitioner acknowledged:
(1) he had a substantial income tax due and owing to
the United States for the year 1989;
(2) he made an affirmative attempt to evade that tax by
failing to file an income tax return and pay the taxes
owing for that year and by engaging in the following
affirmative acts alleged in the information, namely–-
dealing extensively in cash and money orders, using
nominees to make certain expenditures, and structuring
a currency transaction in excess of $10,000 to avoid
the filing of a currency transaction report; and
(3) he acted willfully and with the intent to defraud
the government of the additional unreported taxes.
Unger also acknowledges that he engaged in similar
relevant criminal conduct with respect to his 1987 and
1990 income taxes.
Petitioner maintained multiple bank accounts. Some of the
accounts were held in his own name, numerous accounts were held
jointly with his mother, Helen Unger, and still others were in
his mother’s name alone (collectively petitioner’s bank
accounts). Petitioner had access to the joint accounts and the
bank accounts styled in his mother’s name and provided funds that
2(...continued)
SEC. 7201. ATTEMPT TO EVADE OR DEFEAT TAX.
Any person who willfully attempts in any manner to
evade or defeat any tax imposed by this title or the
payment thereof shall, in addition to other penalties
provided by law, be guilty of a felony and, upon
conviction thereof, shall be fined not more than
$100,000 ($500,000 in the case of a corporation), or
imprisoned not more than 5 years, or both, together
with the costs of prosecution.
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