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knowledge that the income was not properly reported.
Toward the end of the calendar year for each of his 1990,
1991, 1992, and 1993 taxable years, petitioner accessed the
computer program utilized by the Bank and created entries for
mortgage loan interest payments which did not exist. Petitioner
caused false interest expenses to be reported and false Forms
1098, Mortgage Interest Statement, to be filed with respondent
for petitioner’s 1990, 1991, 1992, and 1993 taxable years.
Petitioner utilized the false reported mortgage interest expense
information to claim false deductions on his 1990, 1991, 1992,
and 1993 returns in the following amounts:
Year Amount
1990 $5,645
1991 7,424
1992 7,294
1993 7,149
On November 13, 1995, petitioner pleaded guilty to two
counts of an Information in Case No. 95-Cr-188 in the United
States District Court of the Eastern District of Wisconsin.
Count One of the plea agreement charged petitioner with
“knowingly and willfully [scheming] to conceal a material fact
from agencies of the federal government”, in violation of 18
U.S.C. sec. 1001 (1994). The material fact concealed was the
true amount of interest earned by petitioner, Lois Posnanski, and
petitioner’s mother, Mary Posnanski. Count One also charged
petitioner with falsifying bank records pertaining to loan
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