United States v. Crim

EXPLANATION AND ORDER

ANITA B. BRODY, District Judge.

I. Background

On January 28, 2008, a jury convicted Defendant John Brownlee (“Defendant” or “Brownlee”) of one count of conspiring to defraud the United States, in violation of 18 U.S.C. § 371 (a “Klein” conspiracy, after U.S. v. Klein, 247 F.2d 908 (2d Cir.1957)), and one count of corruptly endeavoring to interfere with the administration of the internal revenue laws, in violation of 26 U.S.C. § 7212(a). These convictions stemmed from evidence of Brownlee’s involvement with Commonwealth Trust Company (“CTC”), a company that sold sham…