Yet another plea was entered yesterday. The DOJ Tax Press Release is here. The key facts form the DOJ Tax Press Release and the Plea Agreements (below) are.
Taxpayers: Sean Roberts & Nadia Roberts, husband and wife.
Banks : UBS AG, an unnamed Isle of Man Branch of UK bank, an unnamed Lichtenstein bank, an unnamed Hong Kong bank, an unnamed bank in New Zealand and an unnamed bank in South Africa.
Entities: Yes.
Guilt: By Plea Agreement - Tax Perjury (one count).
Tax Loss: $709,765 (includes relevant conduct beyond the year of conviction)
Restitution: $709,675 (joint between the two; will be credited to tax due)
Cooperation: Agreement to cooperate in (i) determining tax liability for 2003 forward (note the tax loss and restitution are just a floor.); and (ii) in "investigation and proseuction of other individuals involved in possible violation of federal and state law." The latter is coupled with the usual non-committal 5K1.1 departure for cooperation.
Enablers (in addition to the banks): Isle of Man cororate and trust services company; UBS BANKER C.U.; ACCCOUNT MANAGER B.S., owner of a Zurich based financial services company. (Substantial in U.S. activity by the individuals.)
FBAR penalty: 50% of highest amount for one year.
Court: ED CA.
Judge: Anthony W. Ishi.
Documents:
Husband Information
Husband Plea Agreement
Wife Information
Wife Plea Agreement
Tuesday, June 21, 2011
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In computing the highest balances, the amounts in the bank are clear. But how about the secuties and bonds? Do you take the cost value and add to the bank balances or do you tkae the market values and add to the bank amounts?
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