UNITED STATES DISTRICT COURT
(26 U.S.C. § 7201)
The United States of America, acting through its attorneys, charges:
That on or about each of the filing dates set forth below, in the District of Connecticut, Richard Sanislo, a resident of Avon, Connecticut and a former purchasing agent of display materials for Heublein, Inc., did unlawfully, willfully and knowingly attempt to evade and defeat a large part of the income tax due and owing by him to the United States of America for each of the calendar years 1989 through 1993, by filing and causing to be filed with the Director, Internal Revenue Service Center, at Andover, Massachusetts, false and fraudulent U.S. Individual Income Tax Returns, Forms 1040, wherein he failed to report as income kickbacks he received from various vendors of display materials, and wherein he stated that his taxable income was for the sums set forth below, and that the amount of taxes due and owing thereon was for the sums set forth below; whereas, as he then and there well knew and believed, his true taxable income as set forth below for said calendar years was substantially in excess of the specific sums reported, upon which said taxable income there was owing to the United States of America an additional income tax as set forth below:
In violation of Title 26, United States Code, Section 7201.