📧 Communication

This legal document, a page from a letter to Judge William H. Pauley, III, argues that a defendant named David was not a culpable participant in the illegal aspects of the Jenkins tax shelter scheme. The author contends that David's acquittal on conspiracy and tax evasion charges, along with his co-defendant's full acquittal, shows the jury believed David did not know the shelters were illegal. The document attributes David's belief in the shelters' legality to high-level approval from Deutsche Bank and the belief that a legal "loophole" had been found, suggesting his convictions for mail fraud and tax obstruction were solely for separate "backdating" transactions.