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INDICTMENT
COUNT ONE
JEFFREY BLACKWELL
willfully made and subscribed a United States income tax return, Form 1040, for the calendar
year 2012, which was verified by a written declaration that it was made under the penalty of
perjury and filed with the Director, Internal Revenue Service Center, at Philadelphia,
Pennsylvania, which defendant BLACKWELL did not believe to be true and correct as to every
material matter, in that the return claimed T.W., a person known to the Grand Jury, as a
dependent on line 6c, and claimed unreimbursed travel·expenses on lines 2 and 3 of Form 2106-
EZ, when, as defendant BLACKWELL knew, T.W. was not a dependent of defendant
BLACKWELL, and defendant BLACKWELL did not incur the travel expenses claimed on
Form 2106-EZ.
2015, defendant JEFFREY BLACKWELL received gross income consisting of a salary from the
City of Philadelphia, payments from a business he owned, and payments from individuals hoping
2. During the calendar years set forth below, in Philadelphia, in the Eastern
JEFFREY BLACKWELL,
a resident of Ph.iladelphia, had and received gross income substantially in excess of the minimum
filing requirement, as set forth below, and that by reason of such gross income he was required
by law, following the close of each calendar year and on or before April 15 of the following year,
to make an income tax return to the Director, Internal Revenue Service Center, at Philadelphia,
Pennsylvania, or other proper officer of the United States, stating specifically the items of his
gross income and any deductions and credits to which he was entitled; that knowing this, he
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Case 2:19-cr-00318-CFK Document 1 Filed 06/04/19 Page 3 of 3
willfully failed to make an income tax return to the Director of the Internal Revenue Service
GROSS INCOME
COUNT YEAR FILING REQUIREMENT
2 2014 $20,300
3 2015 $20,600
A TRUE BILL:
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WILLIAM M. McSW AIN
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UNITED STATES ATTORNEY