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Case 3:18-cr-00494-HZ Document 1 Filed 10/17/18 Page 1 of 6

FILED17 [( 1014:481J$DC-ORP
1

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA 3:18-cr- c)QL\9 4 -l+L-
v. INDICTMENT

BRUCE L. LAMON, 26 u.s.c. § 7201
18 u.s.c. § 1001
Defendant.

THE GRAND JURY CHARGES:

COUNT!
(Tax Evasion)
(26 u.s.c. § 7201)

At all times relevant to this Indictment,

General Allegations

1. Between 2006 and August 2012, defendant BRUCE L. LAMON was an attorney

and worked as a commercial litigator for a law firm in Honolulu, Hawaii.

2. In August 2012, defendant BRUCE L. LAMON retired from his law firm. At

the time of his retirement, defendant LAMON owned and controlled a retirement investment

account valued at approximately $395 ,000.

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3. Defendant LAMON did not timely file his individual income tax returns for

calendar tax years 2008, 2009, 2010, 2011, 2012, or 2013, as required by the Internal Revenue

Code.

4. In February 2013 , the Internal Revenue Service (IRS) issued to defendant

LAMON an assessment of $112,040 for calendar tax year 2008.

5. In July 2014 and August 2014, the IRS placed levies on several bank accounts

defendant LAMON owned and/or controlled.

6. In late July 2014, defendant LAMON came to an IRS office in Portland, Oregon,

and had a conversation with an IRS Revenue Officer about defendant LAMON'S untiled

individual income tax' returns.

7. In August 2014, defendant LAMON filed with the IRS his individual income tax

returns for calendar tax years 2009, 2010, 2011 , and 2012. On these tax returns, defendant

LAMON reported to the IRS that he owed income tax in the combined amount of approximately

$342,000, but except for having earlier paid $5,000 of the taxes he owed for calendar tax year

2009, defendant LAMON did not pay these taxes.

8._ In January 2015 , defendant LAMON filed with the IRS his individual income tax

return for calendar year 2013 . On this tax return, defendant LAMON reported taxable income of

$410,500 and tax due of $120,321, but defendant LAMON did not pay any of the tax due.

9. As of mid-October 2015 , defendant LAMON had due and owing to the United

States of America, approximately $744,000 in individual income taxes for calendar years 2008,

2009, 2010, 2011 , 2012, and 2013.

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Willful Evasion of Payment of Income Taxes

10. From in or about November 2012 to in or about December 2015, in the District of

Oregon and elsewhere, defendant BRUCE L. LAMON, a resident of Hillsboro, Oregon,

willfully attempted to defeat the payment of income tax due and owing by him to the United

States of America, for calendar years 2008, 2009, 2010, 2011, 2012, and 2013, by committing

the following affirmative acts, among others:

(a) In November 2012, defendant LAMON purchased a cashier's check for $21,065 and

used the cashier's check to purchase a new 2013 Subaru Legacy automobile.

Defendant LAMON then caused this automobile to be titled and registered solely in

the name of his wife to conceal this asset from the IRS .

(b) In April 2013 , defendant LAMON purchased a cashier's check for $12,500 and used

the cashier' s check, $13 ,848 in cash, and a trade-in automobile, to purchase a new

2013 Toyota Prius automobile. Defendant LAMON then caused this automobile to

be titled and registered solely in the name of his former wife (their divorce became

final before the automobile purchase) to conceal that asset from the IRS.

(c) In June 2013, while residing in Oregon, defendant LAMON registered a business

named Ward Hill LLC with the State of Hawaii.

(d) On July 5, 2013, defendant LAMON purchased at a sheriffs sale a residence located

in Beaverton, Oregon. To conceal from the IRS his ownership of, and association

with, this property, defendant LAMON purchased this property in the name of Ward

Hill LLC. To further conceal from the IRS his ownership of, and association with,

this property, defendant LAMON paid for the property using $72,000 in cash. To

further conceal from the IRS his ownership of, and association with, this property,
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defendant LAMON caused the property ownership records of the county registry of

deeds and of the county tax assessor to show that the previous owner of the property

continued to own this property after defendant LAMON took possession and control

of the property and rented it to tenants.

(e) On July 10, 2013, defendant LAMON purchased at a sheriffs sale a residence

located in Hillsboro, Oregon. To conceal from the IRS his ownership of, and

association with, this property, defendant LAMON purchased this property in the

name of Ward Hill LLC. To further conceal from the IRS his ownership of, and

association with, this property, defendant LAMON caused the property ownership

records of the county registry of deeds and of the comity tax assessor to show that the

previous owner of the property continued to own this property after defendant

LAMON took possession and control of the property and rented it to tenants.

(f) On September 5, 2013, defendant LAMON purchased at a sheriffs sale a residence

located in Portland, Oregon. To copceal from the IRS his ownership of, and

association with, this property, defendant LAMON purchased this property in the

name of Ward Hill LLC. To further conceal from the IRS his ownership of, and

association with, this property, defendant LAMON paid for the property using

$88,001 in cash. To further conceal from the IRS his ownership of, and association

with, this property, defendant LAMON caused the property ownership records of the

county registry of deeds and of the county tax assessor to show that the previous

owner of the property continued to own this property after defendant LAMON took

possession and control of the property and rented it to tenants.

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(g) In 2014 and 2015, defendant LAMON collected a substantial amount ofrent from

tenants who rented the three properties he purchased at sheriffs sales. To conceal

this rental income from the IRS, defendant LAMON did not deposit to a bank

account a large portion of the rental income and, instead, used the undeposited rent

for personal expenditures.

(h) From August 2012 through mid-October 2015, defendant LAMON withdrew a total

of approximately $490,000 in cash from bank accounts he owned or controlled, with

most withdrawals being between $5,000 and $20,000, each such withdrawal being a

separate affirmative act to evade payment of income taxes.

(i) On or about February 10, 2015, defendant LAMON traded in the 2013 Toyota Prius

automobile described in subparagraph (b), above, for a 2015 Hyundai Accent

automobile. Also on February 10, 2015, defendant LAMON caused this Hyundai

Accent automobile to be titled solely in the name of his former wife in order to

conceal from the IRS his ownership of this asset.

In violation of Title 26, United States Code, Section 7201.

COUNT2
(False Statement)
(18 u.s.c. § 1001)

On or about May 11 , 2016, in connection with Bruce Lamon v. National Transportation

Safety Board, Case No. 3: l 6-cv-00821-HZ, filed in the United States District Court for the

District of Oregon, defendant BRUCE L. LAMON knowingly and willfully made and used a

false writing or document knowing the same to contain a materially false, fictitious , or fraudulent

entry, that is, defendant LAMON filed with the

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Court an Application to Proceed In Forma Pauperis (ECF No. 2) in which he responded "no" to

the question "In the past 12 months have you received any money from any of the following

sources? .. . Rent payments, interest, or dividends", when defendant LAMON had, in the past

12 months, been regularly receiving rent payments from tenants of the rental properties identified

in subparagraphs l0(d), l0(e), and l0(f) of Count 1, above .

In violation of Title 28, United States Code, Section 1001.

Dated: October __11,_, 2018 .

Presented by:

BILLY J. WILLIAMS

Assistant United States Attorney

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