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655 KB
Extraction Summary
5
People
3
Organizations
0
Locations
3
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal filing / court document (sentencing memorandum or government submission)
File Size:
655 KB
Summary
This document is a page from a 2013 legal filing (likely a sentencing memorandum) concerning the tax fraud case of United States v. Daugerdas et al. It details the conviction of David Parse for obstructing the IRS and mail fraud, noting he faces a statutory maximum of 23 years in prison. While this document is included in the unsealed bundle for the Giuffre v. Maxwell case (Case 1:20-cv-00330), the text specifically addresses the legal proceedings and sentencing guidelines of the Daugerdas tax shelter scheme, likely serving as a legal exhibit or precedent within the broader Maxwell litigation.
People (5)
| Name | Role | Context |
|---|---|---|
| David Parse | Defendant |
Convicted of obstructing the IRS and mail fraud; facing sentencing.
|
| Guerin | Co-defendant |
Charged in the third superseding indictment.
|
| Daugerdas | Co-defendant |
Charged in the third superseding indictment.
|
| Mayer | Co-defendant |
Charged in the third superseding indictment.
|
| Brubaker | Co-defendant |
Charged in the third superseding indictment.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| IRS |
Internal Revenue Service; victim of the defrauding conspiracy.
|
|
| Probation Office |
Prepared the Presentence Investigation Report (PSR).
|
|
| Grand Jury |
Returned the third superseding indictment.
|
Timeline (3 events)
Relationships (4)
Charged together in indictment
Charged together in indictment
Charged together in indictment
Charged together in indictment
Key Quotes (3)
"Given this clear legal imperative, Parse’s willingness to participate in such conduct can only be viewed as brazen misconduct."Source
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Quote #1
"Parse in particular was charged with a conspiracy to the defraud the IRS, to commit tax evasion, and to commit mail and wire fraud"Source
DOJ-OGR-00009534.jpg
Quote #2
"As calculated by Probation, the final offense level is 40, calling for a Sentencing Guidelines sentence at the statutory maximum, 23 years’ imprisonment."Source
DOJ-OGR-00009534.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,023 characters)
Case 1:20-cv-00330-PAE Document 616-3 Filed 02/24/22 Page 115 of 117
A-6083
A-6083
Case 1:09-cr-00581-WHP Document 605 Filed 03/18/13 Page 10 of 41
conversations with David Parse, that the steps of the transactions had to be completed by the end of
the year to achieve the tax benefits. Given this clear legal imperative, Parse’s willingness to
participate in such conduct can only be viewed as brazen misconduct.
the year to achieve the tax benefits. Given this clear legal imperative, Parse’s willingness to
participate in such conduct can only be viewed as brazen misconduct.
C. The Indictment, Trial, New Trial Rulings, and the PSR
On March 4, 2010, the grand jury returned a third superseding Indictment charging Parse,
Guerin, Daugerdas, Mayer, and Brubaker in thirty-one counts. Parse in particular was charged with
a conspiracy to the defraud the IRS, to commit tax evasion, and to commit mail and wire fraud
(Count One), as well as three counts of tax evasion relating to the tax shelter transactions of three
separate tax shelter clients (Counts Seventeen, Eighteen, and Nineteen). Parse was also charged in
Counts Twenty and Twenty-Five with engaging in a corrupt endeavor to obstruct and impede the IRS
and mail fraud, respectively, essentially through the same conduct underlying the Count One
conspiracy charge.
Guerin, Daugerdas, Mayer, and Brubaker in thirty-one counts. Parse in particular was charged with
a conspiracy to the defraud the IRS, to commit tax evasion, and to commit mail and wire fraud
(Count One), as well as three counts of tax evasion relating to the tax shelter transactions of three
separate tax shelter clients (Counts Seventeen, Eighteen, and Nineteen). Parse was also charged in
Counts Twenty and Twenty-Five with engaging in a corrupt endeavor to obstruct and impede the IRS
and mail fraud, respectively, essentially through the same conduct underlying the Count One
conspiracy charge.
On February 28, 2011, trial commenced against Parse and his co-defendants. On May 24,
2011, the jury found Parse guilty on Counts Twenty and Twenty-Five, and not guilty on Count One
and Counts Seventeen through Nineteen. Subsequently, the Court denied Parse motions for new trial
based on juror misconduct and ineffective assistance of counsel. As a result of Parse’s convictions,
he faces a maximum of 23 years in prison.
2011, the jury found Parse guilty on Counts Twenty and Twenty-Five, and not guilty on Count One
and Counts Seventeen through Nineteen. Subsequently, the Court denied Parse motions for new trial
based on juror misconduct and ineffective assistance of counsel. As a result of Parse’s convictions,
he faces a maximum of 23 years in prison.
In connection with Parse’s sentencing, the Probation Office has prepared a Presentence
Investigation Report (the “PSR”), which calculates the defendant’s Sentencing Guidelines offense
levels. As calculated by Probation, the final offense level is 40, calling for a Sentencing Guidelines
sentence at the statutory maximum, 23 years’ imprisonment. PSR ¶ 103. The breakdown of Parse’s
Guidelines calculation is as follows:
Investigation Report (the “PSR”), which calculates the defendant’s Sentencing Guidelines offense
levels. As calculated by Probation, the final offense level is 40, calling for a Sentencing Guidelines
sentence at the statutory maximum, 23 years’ imprisonment. PSR ¶ 103. The breakdown of Parse’s
Guidelines calculation is as follows:
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DOJ-OGR-00009534
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