Leatherstocking 1983 Partnership, Sam I. Brown, A Partner Other Than The Tax Matters Partner - Page 9

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          charged Steele with one count of structuring the transactions in            
          the First Hi-Tech account to evade the currency transaction                 
          reporting requirements of 31 U.S.C. sec. 5313(a), in violation of           
          31 U.S.C. secs. 5322(b) and 5324(a)(3) and 18 U.S.C. sec. 2.                
               In September 1992, Steele and the U.S. Attorney for the                
          Southern District of New York agreed that Steele would plead                
          guilty to this information and that the information would be                
          transferred to the District of New Jersey (the resulting case               
          filed as Crim. No. 92-513 (AJL)), so that Steele could be                   
          sentenced in one proceeding on his separate pleas of guilty in              
          New York, New Jersey, and Colorado.  The September 1992 plea                
          agreement stated that if Steele complied with the understandings            
          contained in the agreement, neither the U.S. Attorney for the               
          Southern District of New York nor the Tax Division of the                   
          Department of Justice, as applicable, would prosecute Steele for            
          any crime related to:  (1) His participation in the conspiracy to           
          return Marcos to power in the Philippines, (2) “his failure to              
          report as income millions of dollars he received from Ferdinand             
          Marcos in 1986 and 1987", (3) “the validity of the                          
          Leatherstocking Farm as an entity entered into for profit, and              
          the validity of the [eight] Leatherstocking Partnerships”                   
          (including Leatherstocking), and (4) “his failure to file                   
          personal income tax returns for calendar years 1987 through 1990            
          and his failure to file for Roblis Enterprises Ltd., U.S. Income            






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