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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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