Charles Jerome Posnanski - Page 4

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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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