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Wilson signed the declaration after crossing out the portion that
referred to the Merrill Lynch account because she did not copy
Merrill Lynch statements and had nothing to do with petitioner’s
Merrill Lynch account. After receiving the redacted version of
the declaration, petitioner called Ms. Wilson and asked her why
she had crossed out portions of the declaration. Petitioner
stated that the crossed-out portions regarding her Merrill Lynch
account were the most important part of the declaration.
Petitioner attempted to convince Ms. Wilson that she had copied
the Merrill Lynch documents when she had in fact not copied them.
Petitioner’s Criminal Trial
Petitioner was the defendant in United States v. Ludlow,
Case No. CR-97-727. In the criminal case, petitioner was
indicted on three counts of subscribing false income tax returns
for 1989, 1990, and 1991 in violation of section 7206(1). After
being indicted, during trial, and at sentencing, petitioner was
represented by Deputy Federal Public Defender Victor B. Kenton.
Petitioner’s criminal trial lasted 8 days.
During the criminal proceedings, petitioner admitted that
the seven checks she deposited into her Merrill Lynch account
totaling $20,833 in 1989, $94,335 in 1990, and $8,677 in 1991
represented business income generated by the law firm which
should have been, but was not, reported on her 1989, 1990, and
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