United States v. Manfredi

MEMORANDUM OPINION AND ORDER

NORA BARRY FISCHER, District Judge.

I. INTRODUCTION

On September 25, 2007, a grand jury returned an eight-count indictment against Samuel J. Manfredi (“Mr. Manfredi”) and Marilyn T. Manfredi (“Mrs. Manfredi”) (collectively, “Defendants”) charging both with the following crimes: (1) at Count One with conspiracy to commit offenses against the United States under 18 U.S.C. § 371 including income tax evasion in violation of 26 U.S.C. § 7201, filing false tax returns in violation of 26 U.S.C. § 7206(1) and structuring currency transactions in violation of 31 U.S.C. §…