Ian Christopherson, an attorney and
resident of Las Vegas, was sentenced yesterday to 33 months in prison and
ordered to pay $728,786 in restitution by U.S. District Judge Miranda M. Du,
the Justice Department and Internal Revenue Service (IRS) announced. On Sept.
23, 2011, following a five day trial in Las Vegas, Christopherson was convicted
of two counts of income tax evasion for his federal individual income taxes and
for federal employment taxes.
According to the evidence presented
at trial, from 1994 through 1998, Christopherson ran a small law firm that
employed up to nine individuals. He withheld taxes from each of his employees
during these years, but did not timely file employment tax returns or his own
individual income tax returns. In December 1998, the defendant filed more than
30 delinquent tax returns without making a single payment, even though each of
the tax returns he filed reported that he owed taxes. According to the
individual income tax returns and employment tax returns that Christopherson
filed, he owed the federal government a total of $175,685 in federal taxes. The
total tax loss, including penalties and interest, is $728,786.
Additionally, the evidence at trial
showed that Christopherson spent the next five years engaged in stalling and
diversionary tactics with the IRS. The defendant serially submitted incomplete
Offers in Compromise (OIC) for consideration, only to withdraw them later. He
failed to disclose significant assets in the OIC, including up to $250,000. He
also misrepresented his efforts to file other back tax returns as required by
the IRS.
The evidence at trial further showed
that in August 2002, Christopherson set up a nominee account in the state of
Montana in order to conceal his assets from further collection efforts by the
IRS. Christopherson made use of a bank account under the name of “Industrial
Consultants,” a company owned by friends of his, which was opened solely for
the purpose of assisting Christopherson in evading his taxes. Over the next
five years, Christopherson used this nominee account as his own - depositing
checks from clients, transferring money from his client trust account, and writing
checks for personal and business expenses.
Kathryn Keneally, Assistant Attorney
General for the Justice Department’s Tax Division, commended the IRS-Criminal
Investigation special agents who investigated the case, as well as Tax Division
Assistant Chief Elizabeth C. Hadden and Assistant U.S. Attorney Kathryn C.
Newman, who prosecuted the case.
IRS Circular 230 Disclosure
Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication.
Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication.
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