United States v. John E. Crooks, United States of America v. Joseph R. Laird, Jr., United States of America v. John E. Crooks and Joseph R. Laird

Joseph R. Laird, Jr., appeals his conviction by a jury of conspiracy to defraud the United States ( 18 U.S.C. § 371 ) and of aiding in the filing of false tax returns and of filing false tax returns ( 26 U.S.C. § 7206 (1), (2)). John E. Crooks appeals his conviction by a jury of conspiracy to defraud the United States. We affirm.

FACTS:

Laird was president of Cal Am Corporation (Cal Am), a tax shelter promoter in Encino, California. Crooks, a former law partner of Laird, was attorney for Cal Am. Cal Am sold tax shelter investments purporting to entitle investors to writeoffs on their individual tax returns for mineral royalty payments under a tax shelter scheme devised by Laird.

Under Laird’s scheme, investors were solicited to purchase interests in limited partnerships organized by Cal Am. The limited partnerships owned coal leases. An investor was told that he or she could claim an income tax deduction of more than three times the investor’s original investment because the partnership would make a tax deductible advance mineral royalty payment.

Because the partnerships did not have sufficient funds to make the royalty payments which exceeded the amounts being invested and…