Learning about concealment schemes can help you spot concealed assets your spouse places beyond your reach during your divorce. Therefore, a divorcing spouse trying to identify hidden marital assets / community property could learn a lesson from Dr. Krishnaswami Sriram.  Dr. Sriram is thought to have concealed assets from the IRS in two suspected concealment schemes. The two suspected schemes involved alleged tax fraud. The suspected schemes are thought to have employed these common concealment methods:

• Understating business profits at tax returns & / or overstating business expenses at tax returns.
• Transferring assets from the U.S. to India (use of multiple jurisdictions).
• Parking assets in foreign bank accounts (located in India).
• Maintaining valuable real estate in the names of nominees (i.e. intermediaries).

DR. SRIRAM’s FIRST SUSPECTED ASSET CONCEALMENT SCHEME

Dr. Sriram first concealed assets from the IRS by making false statements at his joint Individual Tax Returns (Form 1040) for years 1997 & 1998.  Additionally, Dr. Sriram made false statements at his Partnership Return Of Income (Form 1065) for year 1999. At these tax returns, Dr. Sriram concealed assets by understating his business profits & / or by overstating business expenses. Consequently, at his September 19, 2002 plea agreement, Dr. Sriram pleaded guilty to violating 26 U.S.C. § 7206(1) (Fraud and false statements).  Furthermore, the plea agreement indicates Dr. Sriram schemed to defraud Medicare, Medicaid and private insurers from about September 1996 until about March 2001. The plea agreement says Dr. Sriram had submitted bogus claims for medical services he never rendered to his patients. Therefore, at his plea agreement Dr. Sriram pleaded guilty to mail fraud & health care fraud besides tax fraud.

DR. SRIRAM’S SECOND SUSPECTED ASSET CONCEALMENT SCHEME

As recently as August 25, 2022, Dr. Sriram was again accused of hiding assets from the IRS. Dr. Sriram’s August 25, 2022 indictment alleges Dr. Sriram violated 26 U.S.C.§ 7201 (Attempt to evade or defeat tax) & 26 U.S.C. §§ 7206(1), & 7206(2) (Fraud & false statements)  The August 25th indictment alleges in relevant part that in 2014 Dr. Sriram entered into a stipulation with the IRS.  Based on the stipulation, the U.S. Tax Court affirmed assessments against Dr. Sriram in the amount of about $1.6 million for years 1997, 1998, 1999 & 2001. Between about June 6, 2014 to about April 2017, Dr. Sriram allegedly tried to reduce the $1.6 million he owed by reportedly making false statements to the IRS.  Moreover, Dr. Sriram’s indictment suggests Dr. Sriram may have hidden his true beneficial ownership of assets by allegedly:

1. Using his children as the nominal owners of rental properties in Arlington Heights, Illinois & Peekskill, NY.  Meanwhile, Dr. Sriram is thought to have secretly controlled these properties and supposedly collected the rental income from these properties.
2. Parking assets in offshore investment accounts in India, at Calibre Consultants Wealth Management and Calibre Financial Financial Services Limited.
3. Transferring about $600,000 from a domestic Bank of America account into a foreign bank account at Federal Bank Limited in India;
4. Titling bank accounts in the names of suspected shell companies which Dr. Sriram secretly controlled.

Copyright 2022 Fred L. Abrams