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26 U.S.C. § 7206(2)
Aiding and Assisting in the Preparation and Presentation
of False and Fraudulent Individual Income Tax Returns
Containing False Deductions - Tabular Form Indictment

IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE ____________ DISTRICT OF ____________

UNITED STATES OF AMERICA

    v.

_______________________

)
)
)
)
)
  
No. __________________
26 U.S.C., § 7206(2)

The grand jury charges:

1. That on or about the dates hereinafter set forth, in the ______________________ District of ______________________, the defendant, [Defendant's Name], a resident of [City], [State], did willfully aid and assist in, and procure, counsel, and advise the preparation and presentation to the Internal Revenue Service, of U.S. Individual Income Tax Returns, Forms 1040, either individual or joint, for the taxpayers and calendar years hereinafter specified, which were false and fraudulent as to material matters, in that they represented that the said taxpayers were entitled under the provisions of the Internal Revenue laws to claim deductions for items and in amounts hereinafter specified, whereas, as the defendant then and there well knew and believed, the said taxpayers were not entitled to claim deductions in said amounts, but of lesser amounts.

2. The allegations of paragraph "1." are repeated and realleged in Counts I through _____, inclusive, of this Indictment, as though fully set forth therein:

COUNT DATE OF OFFENSE TAXPAYER CALENDAR TAX YEAR FALSELY CLAIMED ITEM1 AMOUNT CLAIMED

I._______________________________________________________
II._______________________________________________________
III._______________________________________________________

In violation of Title 26, United States Code, Section 7206(2).

A True Bill.

_________________________
Foreperson

_________________________
United States Attorney


NOTES

1. Where the fraudulent deductions (generally itemized deductions) consist of alleged payments to individuals or organizations, list each fraudulent payment, rather than totalling such payments in the deduction category under which they were claimed on the return. For example, list "Medical Expenses Dr. Jones-$500; Dr. Smith-$500," not, "Medical Expenses $1,000." This will prevent a defense that additional, unclaimed deductions in the same deduction category are available to offset the false items.


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Uploaded April 1998