-10-
Tax Returns for an S Corporation, for the calendar years 1987
through 1990.” In relevant part, the September 1992 agreement
required that Steele: (1) File “accurate” 1986 through 1991
Federal tax returns (or amended tax returns if applicable) for
himself and for Roblis, (2) pay or agree to pay to the Internal
Revenue Service any income tax that is owed by him, by any
related entity, or by any entity that he controls, and any
withholding tax that he failed to pay over to the Internal
Revenue Service from 1983 to present, and (3) “cooperate fully
with the IRS in an expeditious manner in order to resolve his tax
liability and any tax liability and examinations of” entities
that included Leatherstocking, Roblis, and some other entities
related to Leatherstocking. The September 1992 agreement did not
require Steele to sign any of the consents at issue here and
stated specifically that “this Agreement is in no way intended to
require Robert L. Steele to give up any rights he may have to
contest IRS determinations during any administrative or civil
actions”.
On October 6, 1992, Steele pleaded guilty to the one-count
criminal information filed in the Southern District of New York.
On June 4 and July 8, 1993, Steele was sentenced on all three of
the charges to which he had pleaded guilty, and he was ordered to
report to prison on August 27, 1993. Steele’s sentence was 7
years of imprisonment and a $20,000 fine for the charge in
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