THE UNITED STATES ATTORNEY CHARGES:
On or about April 12, 1991, within the Western District of New York, the defendant, XXXX X. XXXXXXXX, did knowingly sell and offer to sell a quantity of prescription drugs within the meaning of Title 21, United States Code, Sections 353(b)(1)(B) and (C), which drugs had been purchased by the Erie County Medical Center, a public hospital located in Buffalo, New York.
All in violation of 21 U.S.C. §§ 353(c)(3)(A)(ii)(I), 331(t) and 333(b)(1).
On or about April 4, 1990, within the Western District of New York, the defendant, XXXXX X. XXXXXXXX, did willfully and knowingly make and subscribe a U.S. Individual Income Tax Return, Form 1040, for the calendar year 1989, which was verified by a written declaration that it was made under the penalties of perjury and was filed with the Internal Revenue Service Center at Andover, Massachusetts, which said Individual Income Tax Return, Form 1040, he did not believe to be true and correct as to every material matter in that the said return reported adjusted gross income for the calendar year of 1989 in the amount of $30,612.74, whereas, as he then and there well knew and believed, said return was false because he had additional taxable income of at least $31,315.99 during the calendar year of 1989, which the defendant knew to be a material amount of income and which he intentionally failed to report on said return, in violation of the law.
In violation of Title 26, United States Code, Section 7206(1).
PATRICK H. NeMOYER
United States Attorney
Western District of New York
[cited in Civil Resource Manual 113]