United States v. Ralph Freedson

Appellant was convicted of conspiring with an unindicted coconspirator, Jackson, to submit false statements and documents to the Internal Revenue Service as part of a “money-laundering” scheme in violation of 18 U.S.C. § 1001 and 18 U.S.C. § 371 . According to the government’s evidence, Jackson launched the scheme by suggesting to a prison acquaintance that appellant, Jackson’s former tax attorney, could “launder” the profits of crime. Jackson arranged a meeting between Jackson’s prison acquaintance (now an FBI informer), FBI agents posing as organized crime figures, and appellant. Appellant described a scheme in which he and Jackson would receive the tainted money, commingle it with trust accounts appellant claimed to manage, invest the commingled funds in commodities transactions, and return half the illegal monies to the agents’ nominees through sham salaries and commissions which would appear to come from legitimate trading in commodities. Negotiations among appellant, Jackson, and the agents continued over the next five months, and culminated in a meeting in San Francisco at which the agents handed appellant a suitcase containing one million dollars in funds to be…