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FILED17 [( 1014:481J$DC-ORP
1
DISTRICT OF OREGON
PORTLAND DIVISION
COUNT!
(Tax Evasion)
(26 u.s.c. § 7201)
General Allegations
1. Between 2006 and August 2012, defendant BRUCE L. LAMON was an attorney
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
Indictment Page 1
Revised March 2018
Case 3:18-cr-00494-HZ Document 1 Filed 10/17/18 Page 2 of 6
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.
5. In July 2014 and August 2014, the IRS placed levies on several bank accounts
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
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
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,
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10. From in or about November 2012 to in or about December 2015, in the District of
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
(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
(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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Case 3:18-cr-00494-HZ Document 1 Filed 10/17/18 Page 4 of 6
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
(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.
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
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Case 3:18-cr-00494-HZ Document 1 Filed 10/17/18 Page 5 of 6
(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
(h) From August 2012 through mid-October 2015, defendant LAMON withdrew a total
most withdrawals being between $5,000 and $20,000, each such withdrawal being a
(i) On or about February 10, 2015, defendant LAMON traded in the 2013 Toyota Prius
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
COUNT2
(False Statement)
(18 u.s.c. § 1001)
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
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Case 3:18-cr-00494-HZ Document 1 Filed 10/17/18 Page 6 of 6
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
Presented by:
BILLY J. WILLIAMS
Indictment Page 6