John A. Rowe and Donna L. Rowe - Page 5




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          charges were dropped because of insufficient evidence of criminal           
          intent.                                                                     
               After his employment with the CFDA ended, Mr. Rowe started             
          his own dental practice, and he also provided dental services               
          through another business.  In April 1995, Mr. Rowe was convicted            
          of Federal money laundering.  He was sentenced to 33 months in              
          prison and ordered to make restitution of $359,452.17 to the Bank           
          of New York.  In November 1997, Mr. Rowe pleaded guilty to 51               
          counts of unlawful compensation under Florida State Medicaid laws           
          and one count of organized fraud.  He was sentenced to 8 months             
          in prison and ordered to make restitution of $5,051.45 to the               
          Department of Health and Human Services.  The 1997 conviction               
          stemmed from unlawful acts performed by Mr. Rowe in connection              
          with providing dental services.                                             
               During her marriage to Mr. Rowe, petitioner was primarily a            
          housewife.  She engaged in occasional work as a substitute                  
          teacher, did some office filing, and volunteered at church.                 
          Petitioner’s personal income during the years in issue was                  
          minimal.  Petitioner has no background in accounting, tax, or               
          other financial matters.  During the years in issue, petitioner             
          did not have expensive jewelry, drive a luxurious car, or wear              
          designer clothes.  Petitioners’ primary residence during the                
          years in issue was sparsely furnished with old office furniture             








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