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 Southern District of New York, Michael W. Heinrich ("Heinrich"), a resident of White Plains, New York and the Director of Purchasing at Philip Morris, Inc. from 1988 until 1991, did unlawfully, willfully and knowingly attempt to evade and defeat a large part of the income tax due and owing by him and his wife to the United States of America for each of the calendar years 1988 through 1990, by filing and causing to be filed with the Internal Revenue Service Center, false and fraudulent U.S. Individual Income Tax Returns, Forms 1040, wherein he and his wife failed to report as income approximately $75,000 in cash he received from Richard Billies, the president of AM-PM Sales Co., Inc., a supplier of display materials to Philip Morris, Inc., and wherein he and his wife stated that their 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, their true taxable income for those calendar years was substantially in excess of the specific sums reported, upon which additional taxable income there was owing to the United States of America substantial additional income tax:
In violation of Title 26, United States Code, Section 7201.