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to evade taxes, (4) the Government contended that Mr. Jacobsen
understated his income for 1987 and 1988 by $58,125, and (5) Mr.
Jacobsen accepted the Government’s calculation of the omitted
income.
For purposes of the sentencing guidelines, Mr. Jacobsen
stipulated that (1) he understated his taxable income in 1987 and
1988 by $58,125, (2) the corresponding tax loss (calculated at 28
percent) was approximately $16,275, and (3) he “employed the same
course of conduct and a common plan with respect to the evasion
of taxes in tax years 1987 and 1988, with the relevant conduct *
* * consisting of the total tax loss in both years even though
the offense of conviction is for tax year 1987.”
In their plea agreements, petitioners acknowledged that the
IRS was not a party to the agreements and that when determining
their civil tax liabilities, the IRS was not bound by the stated
amounts of omitted income in the criminal tax proceeding.
On December 17, 1993, petitioners were convicted of tax
evasion under section 7201 for 1987. They each were sentenced to
6 months’ imprisonment, 2 years’ supervised release, and a $50
special assessment for the Crime Victims’ Fund. As a condition
of the supervised release, petitioners were required to cooperate
with the IRS with regard to civil tax penalties.
Also on December 17, 1993, Mr. Del Bosque was convicted of
conspiring to import a substance containing anabolic steroids.
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