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Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 28 of 37 (Assisting in the Preparation of False United States Individual Income Tax Returns For 2010–2014 Tax Years)

47. Paragraphs 1 through 44 are incorporated here.

48. On or about the dates specified below, in the Eastern District of Virginia and elsewhere, defendant RICHARD W. GATES III willfully and knowingly did aid and assist in, and procure, counsel, and advise the preparation and presentation to the Internal Revenue Service, of a United States Individual Income Tax Return, Form 1040 and Schedule B, of PAUL J. MANAFORT, JR., for the tax years set forth below, which returns were false and fraudulent as to a 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 GATES then and there well knew and believed that MANAFORT 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(2); 18 U.S.C. § 3551 )

(Failure To File Reports Of Foreign Bank And Financial Accounts For Calendar Years 2011–2014)

49. Paragraphs 1 through 44 are incorporated here.

50. On the filing due dates listed below, in the Eastern District of Virginia and elsewhere, 28