Virginia Ferguson, f.k.a. Virginia Del Bosque, and Estate of Armand J. Del Bosque, Deceased, Lori Del Bosque, Special Administrator, et al. - Page 10

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          Bosque worked with Mr. Jacobsen to hide income and evade taxes,             
          (2) in furtherance of his scheme with Mr. Jacobsen, Mr. Del                 
          Bosque filed false tax returns for 1987, 1988, and 1989, (3) Mr.            
          Del Bosque omitted substantial income from those returns with the           
          intent to evade taxes, (4) the Government contended that Mr. Del            
          Bosque understated his income for 1987 through 1989 by $116,499,            
          and (5) Mr. Del Bosque accepted the Government’s calculation of             
          the omitted income.                                                         
               For purposes of the sentencing guidelines, Mr. Del Bosque              
          stipulated that (1) he understated his taxable income in 1987,              
          1988, and 1989 by $116,499, (2) the corresponding tax loss                  
          (calculated at 28 percent) was approximately $32,734, and (3) he            
          “employed the same course of conduct and a common plan with                 
          respect to the evasion of taxes in tax years 1987, 1988, and                
          1989, with the relevant conduct * * * consisting of the total tax           
          loss for all three years even though the offense of conviction is           
          for tax year 1987.”                                                         
               Mr. Jacobsen’s plea agreement set forth the factual basis              
          upon which that agreement was reached.  The agreement stated that           
          (1) from January 1, 1987, through December 31, 1988, Mr. Jacobsen           
          worked with Mr. Del Bosque to hide income and evade taxes, (2) in           
          furtherance of his scheme with Mr. Del Bosque, Mr. Jacobsen filed           
          false tax returns for 1987 and 1988, (3) Mr. Jacobsen omitted               
          substantial income from his 1987 and 1988 returns with the intent           






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