Scheme to defraud in the first degree
Penal code: 190.65(1)(b)
nysenate.gov/legislation/la…

dropbox.com/s/w59f25jz10sx…
From March 2005 - June 2021 defrauded U.S. IRS, NYS Dept. of Taxation and Finance, NYC Dept. of Finance

Another company, Trump Payroll Corp also implicated

Paychecks for Trump, Eric, Junior and Ivanka will all be scrutinized as well as their cash bonuses and perks.
Weisselberg was the biggest beneficiary, as he received $1.76M in indirect employee compensation. He concealed the comp from tax preparers and intentionally omitted it from his tax returns, Federal, State and City.
A total of $901,112 went unpaid, while receiving refunds in the amount of $133,124 total to which he was not entitled.

Beginning in March of 2005 until 6/30/21 Trump Org paid for his rent, parking, and utilities. Weisselberg signed the Trump Org checks to pay for these items.
This is considered employee comp and taxable income. Being and accountant he knew this so can't claim ignorance.

These payments were not recorded in the Trump Corp ledgers as employee comp, instead were noted as "rent expense"
At the same time Trump Corp reduced his paychecks to reflect these off book perks. However in internal ledgers expenses were recorded in some years

Trump Corp not only helped AW evade income tax, they also never disclosed that he lived in NYC so he could evade city taxes
He began to pay city taxes only after the sale of his country NY home in 2013.

In 2012 members of his family attended private schools.
Trump Corp and AW arranged to have tuition payments drawn on the personal account and signed by one DONALD J TRUMP.

This was taxable income.
This again was recorded in internal ledgers as compensation to AW. None of this was reported in his tax returns, nor through Trump or Trump Corp.

From 2005-2017 Mercedes leases for AW and his wife were paid for by Trump Corp. Again, taxable income not recorded.
Another scheme to defraud was holiday compensation paid in cash.

AW cause Trump Corp to issue corp checks made payable to an employee, who then cashed the checks and received cash, which was then given to AW for personal use.

Trump Corp booked this as "Holiday Entertainment"
Again, internal ledgers said this was AW comp.

Another scheme to defraud, AW had Trump Corp pay for personal exp for his homes, and one of his children, as well as other employees.

Undisclosed income both on the part of AW, the employees and Trump Corp.
EOY bonus checks for certain employees drawn on other than Trump Payroll Corp payrolls, were class as non-employee comp on 1099 forms, which a co does not withhold taxes on.

By this method AW was able to make annual tax deferred deposits to a Keough Plan for self employed indivs
The Trump Org furthered the scheme by filing the fraudulent 1099's and W-2's
SECOND COUNT

Trump Corp, Trump Payroll Corp and AW the crime of Conspiracy in the Fourth Degree Penal code 105.10(1)

nysenate.gov/legislation/la…
The defendents and the UNINDICTED CO-CONSPIRATOR #1
From March 2005 - 6/20/2021 Grand Larceny in the Second Degree be performed and agreed with one or more persons to engage and cause
The agreed to implement AW and other employees compensation fraud

OVERT ACTS
1. 2005 Trump Corp through its president, entered into an apt lease with a rider desg AW and spouse as sole occupants.

2. April 2010 Unindicted co-conspirator #1 under-reported AW's income for 2009
3 - 9 April 2010, 2011, 2012 2013, 2014, 2015, 2016 AW deposited tax refund which he received by defrauding the government

Sept 2017, AW instructed accounting to remove notations "Per Allen Weisselberg" from the entries in DONALD J TRUMP's detail general ledger relating to
tuition payments for his grandchildren

11 - 12: April 2017, 2018 AW deposited tax refund which he received by defrauding the government

THIRD COUNT
Grand Larceny in the Second Degree Penal code 155.40(1)

nysenate.gov/legislation/la…
From April 2010 - April 2018 AW stole property belonging to the U.S. IRS and the value exceeded $50K

FOURTH COUNT
Criminal Tax Fraud in the Third Degree
Tax law 1804 codes.findlaw.com/ny/tax-law/tax…
April 2015 tax fraud

FIFTH COUNT
Criminal Tax Fraud in the Third Degree
April 2016 tax fraud

SIXTH COUNT
Criminal Tax Fraud in the Third Degree
April 2017 tax fraud

SEVENTH COUNT
COUNT
Criminal Tax Fraud in the Third Degree
April 2018 tax fraud
EIGHTH COUNT
Offering a false instrument for filing in the first degree
Penal code 175.35(1)
nysenate.gov/legislation/la…
April 2015 fraudulent NY tax return

NINTH COUNT
Offering a false instrument for filing in the first degree
April 2016 fraudulent NY tax return

TENTH COUNT
Offering a false instrument for filing in the first degree
April 2017 fraudulent NY tax return
ELEVENTH COUNT
Offering a false instrument for filing in the first degree
April 2018 fraudulent NY tax return

TWELFTH COUNT
Falsifying business records in the first degree
Penal code 175.10
nysenate.gov/legislation/la…
April 2016 defendants falsified the business records of an enterprise

THIRTEENTH COUNT
Falsifying business records in the first degree

April 2017 defendants falsified the business records of an enterprise

FOURTENNTH COUNT
Falsifying business records in the first degree
April 2018 defendants falsified the business records of an enterprise

FIFTEENTH COUNT
Trump Corp and AW in Sept 2016 to defraud, alter, erased, obliterated, deleted, removed and destroyed a true entry into the detail general ledger of DONALD J TRUMP with intent to defraud
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