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Document A-5923

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CAC3PARC 21 1 So it's quite clear the jury was entitled to infer that he knew 2 that this was being done to change the results of the tax 3 losses. He also knew, and there is more than a plethora of 4 evidence on this, that each of these tax shelter transactions 5 had to be completed by year end. And that's why, as Mr. Bair 6 testified and others testified, it was a real effort. 7 Sandra Burnside, you might recall, Mr. Daugerdas'1 8 secretary, testified about the avalanche of work that went on 9 in December at the end of the tax years in order to finalize 10 these transactions. Well, that avalanche of work hit the 11 offices of Mr. Parse's desk. And as Carrie Yackee testified, 12 Carrie Yackee's desk as well. 13 So to suggest that he was not aware this was being 14 done in order to defraud the IRS as the true results of the 15 transaction we submit is unsupportable. 16 There was a suggestion in Mr. Shechtman's brief, I 17 don't think he touched on it today, but the suggestion was that 18 these transactions, these as transactions were approved by 19 Deutsche Bank. 20 Well, first of all, Carrie Yackee's testimony here 21 that she was going to Mr. Parse for approval on these 22 transactions. There is also evidence to suggest that anyone 23 other than Mr. Parse and Carrie Yackee at Deutsche Bank knew 24 the full picture of what went on, which was that these 25 transactions for these particular taxpayers were tax shelter SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010178