United States v. Hough, No. 14-12156 (11th Cir. 2015)
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Defendant was convicted of conspiracy to defraud the United States, in violation of 18 U.S.C. 371, and four counts of filing false individual income tax returns, in violation of 26 U.S.C. 7206(1). The court concluded that there was sufficient evidence for a reasonable jury to find that defendant was guilty of conspiracy to defraud the United States where she and her husband owned two medical schools in the Caribbean, made millions of dollars from operating and selling them, and then, instead of reporting and paying taxes on any of that money, the couple followed "a common design" to hide it in multiple offshore accounts. Further, there was sufficient evidence for a reasonable jury to convict defendant of the four counts of filing false individual income tax returns where she failed to disclose her financial interest in foreign
bank accounts. Finally, the district court did not err in denying defendant's motion for a new trial, the district court properly admitted the husband's out-of-court statements, e-mails, and other correspondence under Federal Rule of Evidence 801(d)(2)(E), and the district court did not clearly err by including in the loss amount the tax she owed on the interest, dividends, and capital gains in those accounts. However, the district court should have made a foundational finding as to whether the two entities defendant owned are properly treated as partnerships for the purpose of federal tax purposes. Accordingly, the court affirmed the convictions, vacated the sentence, and remanded for further proceedings.
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