Page:Manafort-indictment-22Feb2018.pdf/31

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 27 of 37 GATES had borrowed MANAFORT's credit card to make the purchases at issue and would pay him back by a date certain.

Statutory Allegations

(Subscribing to False United States Individual Income Tax Returns For 2010–2014 Tax Years)

45.Paragraphs 1 through 44 are incorporated here.

46. On or about the dates specified below, in the Eastern District of Virginia and elsewhere,

defendant PAUL J. MANAFORT, JR., willfully and knowingly did make and subscribe, and aid and abet and cause to be made and subscribed, United States Individual Income Tax Returns, Forms 1040 and Schedule B, for the tax years set forth below, which returns contained and were verified by the written declaration of MANAFORT that they were made under penalties of perjury, and which returns MANAFORT did not believe to be true and correct as to every material matter, in that the returns (a) claimed that MANAFORT did not have a financial interest in and signature and other authority over a financial account in a foreign country and (b) failed to report income, whereas MANAFORT then and there well knew and believed that he had a financial interest in, and signature and other authority over, bank accounts in a foreign country and had earned total income in excess of the reported amounts noted below:

(26 U.S.C. § 7206(l); 18 U.S.C. §§ 2 and 3551 ) 27