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Tax Shelter Fraud
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2d Cir 5th Cir action agent alleged amendment attomey Attorney bank beneﬁt cert chapter charged Circuit affirmed Circuit held civil claim collateral estoppel commercial bribery conduct consent judgment conspiracy corporation court held crime criminal Customs Defendant was convicted defendantís deﬁned deﬁnition denied district court double jeopardy employee enforcement enterprise evidence extortion false Federal Fifth Circuit ﬁle ﬁled ﬁling ﬁnancial institution ﬁnd ﬁnding ﬁne ﬁned ﬁrst forfeited forfeiture funds govemment Hobbs Act illegal income indictment inﬂuence insured intent interstate commerce jurisdiction jury jury instruction loan mail fraud Matthew Bender merchandise money laundering offense oﬂicer pattem of racketeering payment penalty person predicate acts proceeding prosecution pursuant racketeering activity RICO violations scheme Second Circuit Secretary Seventh Circuit Sherman Act speciﬁc Stat statute STATUTORY REFERENCES App subsection Supp tax evasion tax retums tion transaction Travel Act Turkette United United States Code unlawful activity