Ian Christopherson, an attorney and resident of Las Vegas, Nevada 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.
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