How I ended up in the unfortunate position as the subject of an IRS investigation regarding the filing of tax forms pertaining to offshore assets and my experience as the defendant in the subsequent criminal trial
I have consistently and continually maintained my innocence.
Judge Teilborg found for the
defense. "We owed no taxes"
I have been married to my high school sweetheart, Victoria Quiel, for thirty-six (36) years. She has stuck by my side through the entirety of this case. Vicki thought highly of the Government because of her father’s service to the country. She grew up as an Air Force kid living all over the world. Her world was shattered because of the lies the government told about me at trial. She had a breakdown. I thought I had lost her as she became incoherent. I had to take her ER on three different occasions. Her pulse rate was over 120 while she was sitting on the couch doing nothing.
IRS Investigation of UBS……. UBS sells its clients out
I Due to the financial crisis in 2008 UBS Bank received a government bailout of $60 billion dollars in order to prevent the failure of the bank. Days after receiving the bailout from the government UBS settled with the US IRS tax division, admitting that UBS had assisted US taxpayers in avoiding taxes on UBS Bank accounts.
Hillary Rodham Clinton
Hillary Clinton was sworn in as Secretary of State on January 21, 2009. Clinton (as Secretary of State) was summons to Geneva to discuss an urgent matter. UBS reached an agreement with IRS to pay $780 million in criminal fines for offering tax haven accounts for U.S. clients in February 2009. Four thousand four hundred fifty (4,450) names of U.S. tax payors were handed over breaking Swiss law. As part of the agreement, two hundred forty (240) names were released of U.S. taxpayers to DOJ from UBS, my name was in the list unbeknown to me. My case was never reviewed by the IRS or the FBI or anyone to determine criminal intent. No criminal review and no criminal referral! My case went straight to the DOJ and the assumption was guilt. UBS Executives negotiated deferred prosecution, which means no UBS Executive would be processed criminally.
Since the deal was struck, UBS donated $32 million to the Clinton Foundation and $1.5 million in speaking fees to President Bill Clinton.
Swiss Bank Investment
Rusch / Reeves solicited me to invest into his Swiss Bank. I contributed shares of stock worth over two million. Documentation provided by Rusch said I owned 4% of his bank. This was described in emails and documentation, and he explained it was his responsibility to file all other reporting. To my knowledge, I owned 4% of the bank, which is not required to file ownership. FBAR reporting triggers at 50% ownership. When Rusch / Reeves testified, he stated that I owned 100% of the bank. Imagine if you own 4% of a mutual fund, money was stolen, and you were accused of owning 100% and then had to go through this entire ordeal after losing your entire investment. That is exactly what happened here.
After the financial crisis of 2008, real estate prices had fallen 60% in the Phoenix area. I saw this as a good opportunity to invest in real estate, so I contacted my trusted Attorney Rusch / Reeves to set up a Real Estate Venture Fund in hope of attracting Swiss financing. I would be operating the companies in the United States. I bought nearly 100 properties and solicited my friends and associates to invest into the Hedge Fund. The Hedge Fund was up 35% in the first year of operation. I filed and paid U.S. and State tax returns on this CAYMAN ISLAND investment fund structure recommended by Rusch / Reeves. The difference between the Hedge Fund was, I was in control of this venture unlike the Rusch / Reeves Swiss Bank.
The Indictment, Arrest, and Publicity
The indictment was sealed and filed with the U.S. District Court of Arizona on December 8, 2011 and a warrant was issued for my arrest on Sunday, January 29, 2012. That day five agents arrested me while I was golfing and took me to 4th Street County Jail, and because I was arrested on a Sunday, I was held overnight with the typical Sunday night crowd of drunks and drug addicts until the U.S. Marshall office opened Monday morning at 10AM. The judge determined no bail was needed and I was processed, released and put on pretrial probation.
Wrong Indictment / Paperwork
The indictment was incorrect. They indicted me on the wrong section of the tax return. The Judge allowed the Department of Justice to amend their indictment while we were in trial.
Attorney Christopher Rusch / Reeves Arrest
After the indictment, Rusch / Reeves abandoned his wife and daughter and fled to Panama. When he landed at Tocumen Airport in Panama, officials were waiting for him at the end of the jetway. He was arrested and extradited back to the United States. Upon arriving in Florida, they used “diesel therapy” on a bus until he got to Florence, Arizona. He was held for more than six weeks without being arraigned and without being formally charged of a crime. He was incarcerated with general population of murderers, thugs, rapists and gangs, etc. until he would “cooperate”. After 5 months, he decided to sing their song and testify against his clients. He was then released on bail.
Disclosure of Social Security Numbers
The Pacer System (Pacer is the court filing system used to file court filings and evidence) that the prosecutors posted evidence to, had my tax returns. It explicitly states that any personal information should be redacted from the system. My tax return was not redacted, and the evidence was published all over of the internet with my children’s social security numbers. One of my children had her identity stolen because of the “mistake”.
I backed up my server at a special data company in 2010 when I found out I was under investigation. It cost $30,000 to backup and secure my data. I did not want to be charged with obstruction. I am an honest taxpayer and I knew to preserve data and documents. I complied with all subpoenas for all records. Hillary Clinton is an attorney and has been involved in so many investigations as a Senator and Secretary of State and she had the knowledge to preserve her records. She deleted her files! If her last name was Quiel, Smith or your name she would be in prison for 20 years and would never be heard from again.
Judge James Teilborg
William Jefferson Clinton was elected president in 1992. President Clinton nominated Judge James Teilborg on July 21, 2000. In the last order from Judge Teilborg, after brought to his attention, he lied about my requests for my Internal Master File from the IRS. Judge Teilborg had the opportunity to compel the IRS to get my IMF, but instead, Judge Teilborg stated if I would have requested the files prior to appeal, and received them, I would have evidence they did exist. Thus, the Court would not reconsider the claim because it “involves information that could have learned…… prior to trial”. This is a blatant lie because not only did we request the IMF file before the trial, we requested the file during the trial, and after the trial. The trial transcript validates my claim. I obtained my IMF file in February 2020, nearly 7 years after my trial.
IRS Cheryl Bradley / Christopher Rusch / Reeves Consipracy
IRS Agent Cheryl Bradley had worked with Rusch / Reeves on an audit completed in 2006. This was prior to my trial for my tax years 2000 – 2003. My request for my IMF file before, during and after trial continued for eight years. They purposely did not include these returns in evidence but only testified about them. The reason I wanted my IMF file was because the forms that Rusch / Reeves filed on my behalf, proved Cheryl Bradley and Rusch / Reeves lied. Rusch / Reeves testified he checked the box and filed an FBARs for the same years (2000 – 2003). Cheryl Bradley verified his testimony and stated she received them. The only problem was the years they testified about, the box was not checked and no FBARs exist. They FABRICATED evidence so they could tell the jury that I was fully aware of what forms to file while they conspired the lie of importance of tax forms, they accuse me of filing incorrectly. THIS IS THE EXACT SECTION OF THE RETURN I WENT TO PRISON FOR. THE EXPERTS LIED!
The trial started on March 5, 2013 and lasted five weeks. Four weeks of testimony was from the government spouting securities fraud when that was never charged. The key witness for the prosecution was MY Attorney Rusch / Reeves, who had reached a settlement with the government that he would plead guilty and cooperate with the investigation in exchange for a lesser sentence and immunity on other charges. The whole trial took an emotional toll on my wife, especially since her father just passed, dying for our country.
In the beginning of the trial, the prosecutors asked to use the word “fraud” separately because of the Tax Returns. The Judge granted the request. The prosecutors also asked the Judge if they could use “securities” because I donated stock to fund Rusch / Reeves bank. The Judge granted their request. Immediately upon approval of both words separated, Judge Teilborg allowed “security fraud” to be referenced throughout the entire trial in front of the jury. For four weeks the jury heard “securities fraud” when securities fraud was never charged.
Switzerland Form A
Per Swiss Law, any foreign bank must retain a Form A on file signed by the beneficial owner. This is needed in order to open and maintain an account. UBS did NOT have a form A with my signature! I was unaware of the form A and never signed the form. UBS Bank never contacted me! They only corresponded to Rusch Reeves. Rusch / Reeves stole my identity and put my name on his corporate bank accounts, unbeknownst to me.
IRS Tax Refund $500K
At the request of my defense council, Michael Minns, I wrote a check on August 7, 2012 prior to trial for $500,000 to the IRS, in the event I owed any money to the IRS for any reason On November 12, 2012, the IRS issued a refund check back for the same amount, $500,000. I did not cash the check prior to trial and the UNCASHED REFUND check was in evidence for the jurors to see.
Prior to trial and before Rusch / Reeves fled to Panama, Rusch / Reeves sat down at a meeting with defense council Michael Minns. During the meeting Rusch / Reeves described in detail, that Quiel would have had no idea to file anything. Any shortcoming from this investigation would be derived from when he set up the Swiss Banks paperwork and not following through. Rusch / Reeves stated Quiel did nothing wrong. That tape was played at the jury to discredit Rusch / Reeves.
The lead juror was the only male on the jury. During the juror selection he stated he was a manager at a convenience store. When the backgrounds came back, the juror was a manager with Cricket. He as very modest about his employment along as well as his education.
My friends and business associates wrote over one hundred (100) letters to the Judge for sentencing saying that they were prosecuting the wrong guy. They all confirmed I was honest and had faith in my morals and ethics. I had not cheated them or anyone they knew, and all stood up for me. Six (6) of the letters where from Attorney’s I had hired in the past. Even during trial, the jury was told I hired over fifty (50) professionals to make sure I was compliant with every transaction. The government theory was I only hired one to break the law.
ZERO Taxes Due
Two (2) different Forensic Accountants examined all the documents and made calculations of tax positions related to the years 2007 and 2008 for the purpose of determining the tax liabilities. Their calculations were conducted in accordance with tax preparation techniques. Based on the results of their calculations, they found sufficient evidence to support the conclusion that I owe ZERO net tax. If the unidentified deposits resulting expenditures and losses were included substantial refunds would be granted.
After five weeks of the trial, misuse of “securities fraud” terminology, Timothy Stockwell the DOJ Prosecutor, called me a “bank robber” claiming taxes were not paid. We all know taxes were paid because zero taxes were due at sentencing. After I reviewed the transcripts later, the “bank robber” was removed from what was actually said.
Deliberation of Charges
The jury deliberated on April 11, 2013. Of the five felony charges, I was found NOT guilty on Count 1 for Conspiracy to Defraud. I was NOT guilty for counts 8-9, Willful Failure to File FBAR Report of Foreign Bank and Financial Accounts for 2007 and 2008. For Counts 4-5, I was found guilty for Making and Subscribing a False Tax Return for 2007 and 2008 (not checking the box). Rusch / Reeves was my tax attorney and pled guilty to conspiracy. He is the sole conspirator. It is unbelievable the jury can find me guilty of tax forms when I had an expert attorney / tax professional / only conspirator, advise on filing my tax returns.
When they arrested me on January 29, 2012, while being processed, they took my fingerprints and my passport. Once the trial was concluded, they asked for my fingerprints again because they had lost them. Once I completed my sentence, I filed a request for my passport. After several months, the Department of State said they could not find it. I filed a motion to compel the Department of Justice to return my passport. I requested a chain of custody of my passport that it went back to the Department of State. After that motion, the Department of Justice admitted they lost it, and I had to file for a lost passport.
Michael Stuck CPA
Michael Stuck has been my tax preparer since the late 1990’s. Stuck assisted Rusch / Reeves and Cheryl Bradley in the prior audit. Stuck was the tax preparer on all the taxes for the thirteen (13) different corporations I was filing in 2010, including the Hedge Fund, I was managing. The government had Stuck testify at trial and his testimony stated I was always in compliance. His insurance company instructed him not to continue to handle my taxes because of the criminal investigation. Once the investigation was over, Michael Stuck began handling my taxes again and prepares them to this day. If he thought I was trying to cheat, he would NOT have taken over my tax returns again.
Retired Air Force Colonel John Lee
In 2011 when I was under investigation, my Father in Law USAF Ret. Colonel John Lee, was diagnosed with cancer. He passed away in March of 2012. The cancer was directly linked to agent Orange from flying planes delivering in the Vietnam War. This was confirmed by the Air Force after his death. In his last days, I went to see Colonel John Lee and he had been incoherent for days. I walked into the room and he woke up and recognized me immediately. He looked me right in eye and said “I believe in you. Fight the government for yourself and your family”. To this day, that keeps me motivated to follow through for this injustice.
This chapter of my life has gone on for almost ten years. I have hired numerous attorneys to ensure any activity I engage in, is not deceptive or illegal. I can only continue to believe in my integrity, honesty and faith and move forward.
How your tax attorney recommends an investment into a bank, you invest millions, the tax attorney steals the money, says you were trying to avoid taxes, the government send you to prison, now the government wants to charge you taxes your attorney stole.