United States v. Stein

MEMORANDUM OPINION

KAPLAN, District Judge.

This matter is before the Court on a motion by defendants 1 for disclosure of documents. I assume familiarity with the prior opinions in this case.

I

A. The Indictment

The superseding indictment contains forty-six counts. Count One (the “Conspiracy Count”) charges all defendants with conspiracy to defraud the IRS by designing, marketing, and implementing fraudulent tax shelters for wealthy individ ual clients and deliberately concealing those shelters from the IRS. Defendants’ scheme allegedly involved at least four separate tax shelter vehicles, one of…