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18 U.S.C. § 1001
Falsify, Conceal, or Cover Up
by Trick, Scheme, or Device a Material Fact

IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE ____________ DISTRICT OF ____________

UNITED STATES OF AMERICA

    v.

_______________________

)
)
)
)
)
  
No. __________________
18 U.S.C., § 1001

The grand jury charges:

From on or about the ________ day of _____________, 19___, to on or about the _____ day of __________, 19___, in the __________ District of __________, [Defendant's Name], a resident of [City], [State], did willfully and knowingly falsify, conceal, and cover up, by trick, scheme, or device, in a matter within the jurisdiction of a department or agency of the United States, by [Describe Nature of Scheme or Device to Conceal, Including Name and Title of any IRS Employee to Whom False Statement(s) or Representation(s) Were Made; Nature of False Statement(s) or Representation(s); Place and Location Where False Statement(s) or Representation(s) Were Made; and/or Specific False Document(s) Submitted 1], whereas, as [Defendant's Name] then and there well knew and believed, [Describe Correct Facts Relating to False Statement(s), Representation(s), and/or Document(s) 2].

In violation of Title 18, United States Code, Section 1001.

A True Bill.

_________________________
Foreperson

_________________________
United States Attorney


NOTES

1. E.g., "by representing to John Smith, Revenue Officer, Internal Revenue Service, at 33 Main Street, Boston, Massachusetts, that the deductions claimed for contributions were in the amount of $_________, and that eight checks drawn on account number _______________, at __________________ Bank, were issued to make the contributions in the amounts represented on said checks".

2. E.g., "the said eight checks had been altered and were false as to ________________________ (amounts, payees, dates, etc.)".


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Uploaded April 1998