Professional Documents
Culture Documents
Hunter Biden Indictment
Hunter Biden Indictment
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12/07/2023
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TV
12 Plaintiff, I N D I C T M E N T
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The Grand Jury charges:
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INTRODUCTORY ALLEGATIONS
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At times relevant to this Indictment:
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1. Defendant ROBERT HUNTER BIDEN (hereafter “the Defendant”)
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was a Georgetown- and Yale-educated lawyer, lobbyist, consultant, and
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businessperson and, beginning in April 2018, a resident of Los
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Angeles, California.
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2. At times relevant to this Indictment, the Defendant served
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on the board of a Ukrainian industrial conglomerate and a Chinese
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private equity fund. He negotiated and executed contracts and
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agreements for business and legal services that paid millions of
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 2 of 56 Page ID #:2
9 about October 15, 2020, and to evade the assessment of taxes for tax
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 3 of 56 Page ID #:3
14 Chairman”).
17 Business Associate 1’s entity for sourcing deals and for identifying
25 SinoHawk.
26 12. Over the summer of 2017, the Defendant cut out his SinoHawk
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 5 of 56 Page ID #:5
18 Business Associate 3.
19 iv. Skaneateles
2 must either be withheld from wages and paid over to the U.S. Treasury
3 in the year in which income is earned, which is the case with most
5 basis, again during the year in which the income that is taxed is
6 earned. When taxes are filed in the following year, any withholdings
11 audits some tax returns each year, as a practical matter it can only
14 year following the tax year. A taxpayer may request and receive an
15 extension to file his return, which generally makes the due date
16 October 15. Taxpayers are required to pay any taxes owed on April
21 standard IRS form that individual taxpayers use to file their annual
22 income tax returns. The form contains sections that require taxpayers
24 additional taxes are due and owing or whether the filer will receive
25 a tax refund.
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 8 of 56 Page ID #:8
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D. The Defendant knew he had to file and pay taxes.
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28. Because of his varied income streams and to facilitate the
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withholding and payments of taxes to the IRS, the Defendant formed
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Owasco, PC, a C Corporation, in or about 2006. Owasco, PC’s sole
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purpose was to ensure that there were sufficient withholdings from
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 9 of 56 Page ID #:9
1 all the streams of the Defendant’s income to pay his taxes. Instead
3 Defendant directed third parties to pay Owasco, PC, which had its own
4 bank account, any income owed to him. Owasco, PC then used a payroll
7 which it paid over to the IRS, and the Defendant also made quarterly
20 individual income tax return, on IRS Form 1040, where he reported the
21 income he earned from Owasco, PC and other sources, and could pay
22 taxes on that income using the withholdings Owasco, PC had made, and
23 funds from his tax account. The Defendant also had to file a
24 separate corporate income tax return for Owasco, PC on IRS Form 1120,
25 and could pay any taxes it owed from Owasco, PC’s bank account. This
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 10 of 56 Page ID #:10
3 corporate income tax returns and pay tax on the income that he earned
4 in 2016, 2017, 2018, and 2019. He had done so for tax years 2014 and
5 2015, the two years preceding his scheme to not pay taxes.
7 extension, his 2014 individual income tax return on IRS Form 1040 on
9 having already paid $246,996 to the IRS, the Defendant claimed he was
11 income from Burisma on his 2014 Form 1040. All the money the
13 “ABC”, and was deposited into its bank account. ABC and its bank
17 transfers of funds from the ABC bank account and funds from the ABC
24 extension, his 2015 individual income tax return on IRS Form 1040 on
25 October 17, 2016. The Defendant reported owing $820,801 in taxes and
26 having withheld $644,781, he owed the IRS $176,550. For tax year
28 Form 1040.
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15 and March 2018, he made seven such payments totaling $70,000 but made
2 expenses but not any of his federal individual income tax liabilities
3 for 2016-2019. Between 2016 and October 15, 2020, the Defendant
4 spent this money on drugs, escorts and girlfriends, luxury hotels and
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Summary of Approx. Expenses Made from Owasco, PC and the Defendant’s Bank Accounts
4 (2016 to 2019)
5 Grand
2016 2017 2018 2019
Description Total
6 ATM / Cash
$200,922 $503,614 $772,548 $186,920 $1,664,004
Withdrawal
7 Payments – Various
$4,400 $138,837 $383,548 $156,427 $683,212
Women
8 Clothing &
$78,580 $113,905 $151,459 $53,586 $397,530
Accessories
9 Tuition/
Education/ $117,281 $94,497 $93,213 $4,286 $309,277
10 Extracurricular
Health, Beauty,
$54,789 $110,239 $46,347 $26,121 $237,496
11 Pharmacy
Misc. Retail
$51,629 $75,941 $78,135 $30,929 $236,634
12 Purchases
Food, Groceries,
$67,281 $73,219 $40,590 $33,833 $214,923
13 Restaurants
Insurance $41,808 $47,060 $90,535 $24,412 $203,815
14 Loan / Mortgage
$144,396 $43,647 $500 $3,330 $191,873
Payments
15 Adult
$4,411 $56,846 $100,330 $27,373 $188,960
Entertainment
16 Legal & Accounting
$33,379 $103,745 $9,745 $700 $147,566
Fees
17 Telephone /
$37,319 $29,623 $22,977 $28,521 $118,440
Utilities
18 Rehab (Drug &
$7,600 $28,600 $35,669 $71,869
Alcohol)
19 Wells Fargo
Advisors - Roth $53,000 $53,000
20 IRA
Credit Card
$7,464 $18,479 $12,000 $20,599 $58,542
Payments
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Home Improvement /
$33,168 $3,574 $5,763 $351 $42,856
Maintenance
22 Home Help /
Cleaning / $22,855 $16,946 $39,801
23 Childcare
Entertainment $8,172 $6,148 $7,500 $2,625 $24,445
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Sports /
$22,387 $8 $1,172 $23,567
25 Recreation
Grand Total $990,841 $1,464,928 $1,852,031 $600,013 $4,907,813
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1 F. The Defendant late filed his taxes when facing contempt charges
2 the Arkansas case and in the D.C. Superior Court case to move for
4 court could incarcerate the Defendant for his failure to comply with
5 court orders.
7 that the Defendant appear and show cause why he should not be held in
10 motion for contempt and gave the Defendant until March 1, 2020, to
11 provide the missing records, including his 2017 and 2018 individual
13 45. On or about February 18, 2020, the Defendant late filed his
14 2017 Form 1040. On the 2017 Form 1040, the Defendant reported
15 $1,956,003 in taxable income and $581,713 in tax due and owing. The
16 Defendant chose not to pay any of his outstanding 2017 tax liability
18 46. That same day, the Defendant also late filed his 2018 Form
20 taxable income for 2018 and $620,901 in tax due and owing. The
21 Defendant again chose not to pay any of his outstanding 2018 tax
22 liability when he late filed his 2018 Form 1040 in February 2020.
23 47. On June 12, 2020, the Defendant late filed his 2016 Form
25 taxable income for 2016 and $45,661 in tax due and owing. The
26 Defendant chose not to pay any of his outstanding 2016 tax liability
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1 G. The Defendant had the funds to pay his taxes in 2017, 2018,
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1 COUNT ONE
4 Indictment here.
6 1040 for the Defendant and a Form 1120 for Owasco, PC. The Form 1040
9 left them for the Defendant at his office. Business Associate 4 then
14 Also I just saw last week the unmarked envelope in. The
office e (sic) requiring signatures for my taxes. I wish
15 someone had told me- but its my fault for to (sic) thinking
of that or for having ignored an email im sure Ione (sic)
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of you sent saying there is a large envelope in the office
17 sitting b (sic) the door which requires 50 signatures
including [ex-wife’s] . . .
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57. The Defendant brought the 2016 Form 1040 to his ex-wife and
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asked her to sign it. She said she would, after reviewing the return
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with her accountant. She did so and sent the signed return to the
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Defendant the next day.
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58. On March 9, 2018, the Defendant’s ex-wife texted him that
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she had discovered their unfiled 2016 tax returns in the trunk of his
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car. The Defendant responded telling her, “The taxes are filed those
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were copies with [Personal Assistant 1]’s notes.” The tax returns
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had not been filed. The Defendant’s ex-wife responded telling him
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1 they were not copies because they still had checks attached to them
3 59. On or about July 18, 2018, the IRS received a late filed
4 2016 Form 1120 for Owasco, PC. The Defendant did not submit an
6 E. The Defendant owed taxes for 2016, which he did not timely pay.
7 60. The Defendant owed individual income taxes for 2016 which
8 were due on or before April 18, 2017.
9 61. The Defendant knew he had to pay taxes for the 2016 tax
10 year in 2017 because on or about April 21, 2016, he made a payment of
11 $30,000 towards his 2016 tax liability and on or about April 18,
12 2017, the D.C. Accountant told him he owed an additional $26,000.
13 62. In 2019, as described above, the Defendant retained the CA
14 Accountants. The CA Accountants contacted the IRS on January 22,
15 2020, and learned that the Defendant had not filed an individual
16 income tax return for 2016. They then prepared a Form 1040 for the
17 Defendant, which he reviewed and late filed on June 12, 2020. In that
18 return, the Defendant self-assessed that he owed an additional
19 $45,661 in taxes. He did not pay the $45,661 when he filed in June
20 2020.
21 F. The Defendant had the funds available to pay his taxes when they
22 were due.
23 63. When the Defendant finally filed his 2016 Form 1040, on
24 June 12, 2020, he had funds available to pay some or all of his taxes
25 owed for 2016 but chose not to do so.
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1 COUNT TWO
4 Indictment here.
4 benefit.
5 72. On or about April 16, 2018, the day before his 2017 taxes
8 Defendant “owes a lot of money” for the 2017 tax year and inquired if
9 the Defendant had cash available for tax payments as “he really
11 up a call between the Defendant and D.C. Accountant for the next day.
13 Defendant’s behalf making his tax filings, although not his tax
15 73. For the 2017 tax year, D.C. Accountant prepared the
18 fall of 2018.
23 reminded the Defendant that the tax returns were due and encouraged
24 him to file.
26 Accountant, the Defendant texted his ex-wife that he could not make
27 his alimony payment because “the wire came back due to insufficient
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1 added). The Defendant had not paid his 2017 taxes when he sent that
2 text.
4 Defendant again advising him that his 2017 Form 1040 and Owasco, PC’s
5 2017 Form 1120 were due on October 15 and were late. D.C. Accountant
6 urged the Defendant “to get them filed as soon as possible since late
9 Defendant again advising him that his “2017 tax returns are still
13 Defendant reminding him again that “You need to get 2017 filed so we
15 79. On or about December 10, 2018, the Defendant texted his ex-
17 can pay the taxes, I will pay the taxes. I’m (sic) the meantime I’m
19 added).
21 Personal Assistant 2 and asked her to send him “all auto pay expenses
24 “trying to reach you re: taxes” and she then sent him a breakdown
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 24 of 56 Page ID #:24
2 forwarded him an email from his ex-wife. In the forwarded email, the
8 texted him and requested that the Defendant authorize D.C. Accountant
9 to share the Defendant’s 2017 tax return with her, as the Defendant
11 Agreement. In response, the Defendant told her that, “My tax returns
17 Defendant and the Defendant’s attorney and reminded both that the
18 “2017 tax returns are complete and ready to file. Would you like me
20 E. The Defendant owed taxes for 2017, which he did not pay.
2 18, 2020.
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1 COUNT THREE
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1 COUNT FOUR
4 Indictment here.
26 extension was filed making the tax filings, but not the tax payments,
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1 E. The Defendant owed taxes for 2018, which he did not pay.
4 received the benefit of Personal Friend paying more than $1.2 million
5 of the Defendant’s personal expenses but the Defendant did not direct
7 income taxes.
4 on April 15, 2019, and on February 18, 2020, in the Central District
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1 COUNT FIVE
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1 COUNT SIX
5 A. The Defendant finally filed his 2018 Form 1040 in 2020 in order
2 line of credit”).
5 this letter in which he promised that he had made available “all the
10 responsible for the final “accuracy and completeness for the tax
11 returns.”
13 had none.
14 114. In working with the CA Accountants to prepare the returns,
15 the Defendant claimed business expenses, including approximately
16 $388,810 in business-related travel, despite having done little to no
17 business in that year. At the same time the Defendant was making
18 those representations to the CA Accountants, the Defendant was
19 working on his memoir, which was not published until after he filed
20 his 2018 returns and which he did not share with them. Unbeknownst
21 to the CA Accountants, in his memoir, the Defendant described 2018 as
22 being dominated by crack cocaine use “twenty-four hours a day,
23 smoking every fifteen minutes, seven days a week.” In fact, the
24 Defendant never told the CA Accountants about his extensive drug and
25 alcohol abuse in 2018 which might have prompted greater scrutiny of
26 his claims of hundreds of thousands of dollars in business expenses.
27 115. Rather than conducting business, and generating business
28 expenses, the Defendant wrote in his memoir that after he arrived in
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26 Notably, the Defendant did not write that he conducted any business
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2 purpose.
2 2018; and
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13 fact, the largest line item on the Professional and Outside Services
14 schedule.
15 E. The Defendant falsely claimed that money paid to women with whom
10 with the Defendant after she was placed on payroll. Person 1 received
12 deduction reducing the income to him from Owasco, PC and his individual
13 income taxes. Later, in November 2018, the Defendant had the following
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text exchange with Personal Assistant 2 regarding Person 1:
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THE DEFENDANT: [T]ake [Person 1] off payroll I
16 thought you said she decidedly dint (sic) want
to work and didn’t need health insurance
17 anyway. Remember that conversation?
18 PERSONAL ASSISTANT 2: No. I do not remember
19 that conversation. I remember a conversation
where I was disappointed that you wanted to pay
20 her the same rate as me. But I am over that.
Maybe she told you that but I wasn’t involved.
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THE DEFENDANT: regardless [] thats (sic) was if
22 she was working a 40 hour week full time for
me. I haven’t talked to [Person 1] in 7
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months???????
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b. Person 2 is someone with whom the Defendant had a
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romantic relationship and who did no work, nor was she expected to do
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any work for Owasco, PC. The Defendant placed Person 2 on payroll in
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Spring 2018 in order to provide her with health insurance. In addition
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 40 of 56 Page ID #:40
8 reducing the income to him from Owasco, PC and his individual income
10 Defendant with personal errands and some light clerical work. After
11 being placed on payroll, Person 3 did not perform any work-related
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services.
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d. The Defendant placed Person 4 on payroll in summer 2018.
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Person 4 had a sexual relationship with the Defendant and acted as a
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“West Coast” personal assistant, running errands, and performing other
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6 August 2018;
8 May 2018;
15 A number of these were the very same hotels that the Defendant
18 125. The Defendant also circled a $275 dinner he had with his
22 account ending in 4929 and the Wells Fargo Owasco, LLC account ending
24 were made between April and September 2018. The Defendant used these
27 hotels in Atlantic City, New York City and Los Angeles. Rather, as
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Case 2:23-cr-00599-MCS Document 1 Filed 12/07/23 Page 43 of 56 Page ID #:43
1 he described in his memoir, they were used to meet up with his then-
4 Person 3, totaling $18,400 from his personal Wells Fargo bank account
5 and $10,000 from the Wells Fargo Owasco, LLC account, falsely
7 addition to any money paid to Person 3 for any work she performed and
10 deductions which reduced the income to him from Owasco, PC and his
12 January 28, 2020, the Defendant falsely told the CA Accountants that
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2 July and August 2018. Person 5 “cleaned and [] ran errands, simple
3 things like going to get him some boxers, or get him some food, go
7 wire to Person 4, and the wire details, which the CA Accountants were
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not shown, said $10,000 of it was for a “golf member deposit.” In fact,
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at the Defendant’s direction, the $10,000 was used to purchase a
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membership in a sex club, which he visited with Person 4.
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c. The Defendant made an additional $26,500 in payments
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to Person 4 in June and October, in addition to what she received as
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wages.
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131. Based on the Defendant’s representations, the CA
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Accountants classified the approximately $57,000 in payments from
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Owasco, PC’s Wells Fargo account to JP Morgan Chase as a business
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expense for consulting. This had the effect of reducing the income
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paid to the Defendant from Owasco and reduced his individual income
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taxes.
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H. The Defendant used the business line of credit to pay personal
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expenses and falsely represented to the CA Accountants that it
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was for business expenses.
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132. Similarly, the Defendant also told CA Accountants that
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approximately $119,000 in payments from the Owasco, PC account used
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to pay off the business line of credit had also been for business
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expenses, including travel.
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2 for the business line of credit and repeatedly asked the Defendant to
6 other personal items in New York and in California during 2018, among
8 credit:
14 in New York City for items for himself and his then-girlfriend, in
15 January 2018;
17 in January 2018;
27 and
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2 in January 2018;
3 135. The Defendant also used the business line of credit to make
4 payments for the benefit of his children and his own benefit because
9 136. The Defendant also used the business line of credit to make
19 the business line of credit that would have revealed this to them.
26 liability.
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11 cover email noted that there was “information still outstanding that
19 140. On or about February 11, 2020, the Defendant met with the
21 and corporate income tax returns for 2017 and 2018 with the CA
23 returns. The returns were then mailed to the IRS at the Defendant’s
24 direction.
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3 house rentals for his then-girlfriend, hotel expenses, and New York
28 relationships including a woman who was then pregnant with his child.
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8 have had to report on his 2018 Form 1040 and pay tax on that income.
11 from Owasco, PC, on line 6 of his 2018 Form 1040 and self-assessed a
13 The Charge
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1 COUNT SEVEN
2 [26 U.S.C. § 7206: filing a false and fraudulent 2018 Form 1040]
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1 COUNT EIGHT
2 [26 U.S.C. § 7206: filing a false and fraudulent 2018 Form 1120]
13 information on:
12 club.
20 have had to report on his 2018 Form 1040 and pay tax on that income.
23 from Owasco, PC, on line 6 of his 2018 Form 1040 and self-assessed a
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1 COUNT NINE
4 Indictment here.
24 D. The Defendant owed taxes for 2019, which he chose not to pay.
25 156. The Defendant filed a 2019 From 1040 on October 15, 2020,
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and self-reported that he earned total gross income of $1,045,850 and
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14 F. Rather than pay his taxes, the Defendant spent millions of dollars
15 on an extravagant lifestyle.
16 159. From January through October 15, 2020, the Defendant spent
17 more than $600,000 on personal expenses rather than pay any of the
18 $197,372 he owed for tax year 2019.
19 The Charge
20 160. During the calendar year 2019, the Defendant ROBERT HUNTER
21 BIDEN, had and received taxable income of $843,577, on which taxable
22 income there was owing to the United States of America an income tax
23 of $197,372. He was required by law to pay, on or before July 15,
24 2020, that income tax to the Internal Revenue Service Center, at San
25 Francisco, California, or to another Internal Revenue Service office
26 permitted by the Commissioner of Internal Revenue, including the
27 Internal Revenue Service office in Los Angeles, California. Well
28 knowing all of the foregoing, he did willfully fail on July 15, 2020,
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A TRUE BILL
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/s/
7 Foreperson
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DAVID WEISS
9 Special Counsel
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LEO J. WISE
12 Principal Senior Assistant Special
Counsel
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DEREK E. HINES
14 Senior Assistant Special Counsel
15 United States Department of Justice
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