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participant in the weekly card game could win or lose up to $500.
Also, petitioner regularly bet on football games. In the years
in issue, petitioner averaged two to three visits to the race
track a week, where he bet on horse races. Petitioner and Ms.
McNamara issued checks from their personal joint checking account
at Continental Bank to the following payees:
Payee 1988 1989 1990
Boardwalk Regency Casino $11,500 $1,500 $3,000
Caesars Casino 300 -- --
Crystal Palace (Casino) -- 4,500 --
Resorts International 4,000 -- --
Trump Castle 500 -- --
Carnival Leisure Indus.,
Inc. (d.b.a. Beach -- 10,700 --
Casino)
Total $16,300 $16,700 $3,000
Petitioner was the defendant in the criminal case United
States v. Moran, Criminal Action No. 96-412-1 (E.D. Pa. Aug. 5,
1998). Petitioner was indicted for aiding the filing of false
joint tax returns for himself and Ms. McNamara for the taxable
years 1989 and 1990 in violation of section 7206(2). On October
23, 1996, petitioner pled guilty to these charges. Petitioner
filed a motion to withdraw his guilty plea, which the District
Court denied. On February 21, 1997, the District Court for the
Eastern District of Pennsylvania entered a judgment of conviction
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