DOJ-OGR-00010207.jpg

659 KB

Extraction Summary

5
People
6
Organizations
1
Locations
2
Events
4
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 659 KB
Summary

This legal document, part of a court filing from March 18, 2013, argues for a significant prison sentence for an individual named Parse. It details his central role as a Deutsche Bank representative in a massive criminal tax fraud scheme involving multiple co-conspirators and fraudulent tax shelters, which generated over $7 billion in fraudulent deductions and caused over $230 million in actual losses to the U.S. Treasury. The document highlights that Parse earned over $3 million in commissions for his indispensable role in the scheme.

People (5)

Name Role Context
Parse Investment representative at Deutsche Bank Alex Brown and certified public accountant
Charged individual and key actor in a large criminal tax fraud scheme.
Donna Guerin
Charged alongside Parse in a corrupt endeavor and mail fraud scheme.
Denis Field
Charged alongside Parse in a corrupt endeavor and mail fraud scheme.
Craig Brubaker
Charged alongside Parse in a corrupt endeavor and mail fraud scheme.
Paul Daugerdas
Charged alongside Parse in a mail fraud scheme.

Organizations (6)

Name Type Context
IRS government agency
The entity that was obstructed, impeded, and defrauded by the tax shelter scheme.
Jenkens & Gilchrist company
Associated with the tax shelters mentioned in the mail fraud charge.
Deutsche Bank Alex Brown company
The firm where Parse worked as an investment representative.
United States Treasury government agency
Suffered an actual loss of over $230 million due to the fraud.
Probation Department government agency
Prepared the Presentence Investigation Report ("PSR") regarding Parse's conduct.
Deutsche Bank company
Mentioned as the employer of Parse and other employees who steered clients to tax shelters.

Timeline (2 events)

A wide-ranging corrupt endeavor to obstruct and impede the IRS and defraud the IRS through the design, marketing, implementation, and defense of four tax shelters known as Short Sale, Short Option, SWAPS, and HOMER, as well as the Jenkens & Gilchrist tax shelters.
A trial that demonstrated Parse's role as a key actor in the largest criminal tax fraud in history.

Locations (1)

Location Context
The country whose Treasury suffered an actual loss from the fraud.

Relationships (4)

Parse co-conspirators Donna Guerin
The document states they were charged together in a corrupt endeavor and mail fraud scheme.
Parse co-conspirators Denis Field
The document states they were charged together in a corrupt endeavor and mail fraud scheme.
Parse co-conspirators Craig Brubaker
The document states they were charged together in a corrupt endeavor and mail fraud scheme.
Parse co-conspirators Paul Daugerdas
The document states they were charged together in a mail fraud scheme.

Full Extracted Text

Complete text extracted from the document (1,978 characters)

Case 1:09-cr-00581-WHP Document 605 Filed 03/18/13 Page 4 of 41
A-6077
charged Parse, Donna Guerin, Denis Field and Craig Brubaker with a wide-ranging corrupt endeavor to obstruct and impede the IRS in connection with the design, marketing, implementation, and defense of four tax shelters known as Short Sale, Short Option, SWAPS, and HOMER. Likewise incorporating the factual allegations of the conspiracy count, Count Twenty-Five charged Parse, along with Paul Daugerdas, Guerin, Field, and Brubaker, with mail fraud as to the overarching scheme to defraud the IRS through the design, marketing, implementation, and defense of the Jenkens & Gilchrist tax shelters.
The proof at trial demonstrated that Parse — an investment representative at Deutsche Bank Alex Brown and certified public accountant — participated as a key actor in the largest criminal tax fraud in history. That fraud, which featured Parse’s five-year involvement in four fraudulent tax shelters, resulted in the creation of over $7 billion of fraudulent tax deductions or benefits, $1.6 billion in Guidelines tax loss, and well in excess of $230 million in actual loss to the United States Treasury. Parse’s role in the fraud - as one of the principal Deutsche Bank employees who steered bank clients to the J&G tax shelters, established the evanescent brokerage accounts for those shelters, executed the crucial Treasury short sale and options “investments,” executed the pivotal transfers between accounts, and who helped facilitate the fashioning of the options and other financial instruments used in the shelters - was indispensable to the shelters’ success. Consequently, Parse earned substantial commission income from his role in the tax shelters — over $3 million.
For the reasons spelled out below and in the Probation Department Presentence Investigation Report (“PSR”), we submit that Parse’s conduct, and the resulting harm, is deserving of a significant prison sentence.
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DOJ-OGR-00010207

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