Virginia Ferguson, f.k.a. Virginia Del Bosque, and Estate of Armand J. Del Bosque, Deceased, Lori Del Bosque, Special Administrator, et al. - Page 9

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               In April 1993, Mr. Del Bosque became ill and was diagnosed             
          with cardiomyopathy.  He was hospitalized in a coronary intensive           
          care unit for 9 days.                                                       
               On June 23, 1993, a five-count criminal information was                
          filed in the U.S. District Court for the District of Minnesota              
          (the criminal tax proceeding) naming petitioners codefendants.              
          Counts I, II, and III charged Mr. Del Bosque with tax evasion for           
          1987, 1988, and 1989 in violation of section 7201.  Counts IV and           
          V charged Mr. Jacobsen with tax evasion for 1987 and 1988 in                
          violation of section 7201.                                                  
               Petitioners entered into plea agreements by which                      
          they agreed to plead guilty to tax evasion in 1987 as set forth             
          in counts I and IV, and the Government agreed to move for                   
          dismissal of counts II, III, and V.  Mr. Del Bosque also entered            
          into a plea agreement in his drug case in which he agreed to                
          plead guilty to conspiring to import anabolic steroids.                     
               In the criminal tax proceeding, Mr. Del Bosque acknowledged            
          that his steroid arrest and his illness were contributing factors           
          in his decision to plead guilty to the tax evasion charge and               
          that his medical condition was such that he could not withstand a           
          trial.                                                                      
               Mr. Del Bosque’s plea agreement set forth the factual basis            
          upon which the agreement was reached.  The agreement stated that            
          (1) from January 1, 1987, through December 31, 1989, Mr. Del                






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