United States v. David A. Ruzzano

KANNE, Circuit Judge.

On August 9, 1984, a grand jury in the Northern District of Illinois returned a sixteen count indictment against David A. Ruzzano. Counts fifteen and sixteen, at issue here, charged Ruzzano with tax evasion in violation of 26 U.S.C. § 7201 in the amount of $813,000 and $236,000 for the years of 1979 and 1980 respectively. The indictment was the result of an investigation into Ruzzano’s participation in an oil swindle in which he allegedly promised investors substantial profits on investments in oil producing corporations that did not actually produce oil. At the time of…