§1957

- 5 - ofOhio (1) overruled petitioner's objections to the report and recommendations of the Board ofCommissioners on Grievances and Discipline, (2) concluded that petitioner's Federal crimes involved moral turpitude, and (3) permanently disbarred him from the practice oflaw in Ohio.

Petitioner entered into a plea agreement which did not charge him with underlying knowledge of the Ponzi scheme. Rather, he was charged with aiding and abetting misrepresentations and omissions to investors regarding PCI note transactions. Petitioner was sentenced to 180 months in prison and is currently serving this sentence. - 20 - [*

1957; 2 counts offalse statements to a bank under 18 U.S.C. sec. 1014; 1 count oftheft ofhealthcare funds under 18 U.S.C. sec. 669; and 3 counts oftax evasion under section 7201. Count 20 ofthe indictment (for tax evasion under section 7201) states, in pertinent part: During the period from on or about January 1, 2000, to on or about November

1957, and filing false returns for the years 1992 through 1994 in violation of section 7206(1).4 Convictions for such crimes are highly probative of petitioner’s intent to evade taxes because the activities involve perjury, deceit, breach of fiduciary duty, and concealment of criminal proceeds. See Williams v. Commissioner, T.C. Memo. 1992-153

1957 (1994) (money laundering), section 7206(1) (willfully false statements on a tax return), and 18 U.S.C. sec. 982(a)(1) (1994) (forfeiture). The indictment charging petitioner with violating section 7206(1) pertained to petitioners' 1986 return. Petitioner's case proceeded to trial in the United States District Court, Central District of Ca