- 3 - a downward departure from the sentencing guidelines was therefore appropriate. On July 19, 2000, petitioner appeared before the U.S. District Court for the District of New Jersey and pleaded guilty to violating section 7201 with respect to his 1994 return. In sworn testimony, petitioner gave the following factual basis for his guilty plea. During 1994 and 1995, petitioner was president and owner of an S corporation known as BHN Corp. (BHN), which was engaged in providing computer software-related products to the Dreyfus Corporation. In 1994, petitioner traveled to the Cayman Islands and opened a bank account at the Guardian Bank and Trust (Cayman) in the name of the Cooper Corp. (Cooper). During 1994, he diverted about $651,000 of taxable income from BHN by causing the funds to be deposited into the Cooper account and his personal bank account in New Jersey. Petitioner caused BHN to file a Federal tax return that omitted the $651,000 of income. Petitioner also intentionally failed to include the $651,000 of income on his 1994 personal Federal income tax return, in a knowing and willful attempt to evade and defeat a substantial part of the income tax due and owing to the United States for 1994. The District Court accepted petitioner’s guilty plea and entered judgment finding him guilty of willfully attempting to evade or defeat tax in violation of section 7201 and 18 U.S.C.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: March 27, 2008