An Outlier Offshore Account Tax Obstruction Plea (10/26/12)

I have just recently come across the plea agreement in United States v. Robert Edward Cone (SD TX Crim. No. H-11-617), here.  The plea was entered in February; sentencing is set for early next year.  The plea and my personal knowledge of the case (I represented a witness) indicate that, although a foreign account and the Schedule B foreign account question were involved, the case was an outlier to the Government's foreign account initiative.  Hence, I have put the case in spreadsheet with an indication that it is an atypical case.  First the key data and  then I provide a narrative explanation.

Defendant:  Robert Edward Cone
Banks:  Royal Bank of Canada Jersey Islands)
Entities:  Yes (Jomach Limited, a BVI entity)
High Balance:  ? [See below]
FBAR Penalty: ? [See below]
High Balance:  Unknown
Count of Plea:  Tax perjury, Section 7206(1) with 3 year max sentence
Tax Loss:  $282,691 (agreed as "relevant conduct" tax loss because it was a 2001 liability and the plea count of conviction was for 2006)
Restitution: $939,917 (contractual restitution for the year 2001, consisting of the tax, apparently the civil fraud penalty and tax on each).
5K1 Departure Possibility:  No
Court:  SD TX
Judge:  Ewing Werlein (Wikipedia entry here)