After a three-week trial, Michael Little, a British lawyer licensed in New York, has been found guilty of participating in an 11-year tax fraud scheme.
Little was arrested in 2012, charged with advising and helping an American family defraud the IRS by hiding millions of dollars in overseas Swiss bank accounts and by other means.
According to court records, after the death of investment fund president Harry Seggerman, Little and a lawyer from Switzerland met with his relatives in Manhattan and advised them that Seggerman had left them about $14 million in overseas accounts that had never been declared to U.S. tax authorities. Prosecutors said Little and the Swiss lawyer advised the various family members on steps they could take to continue hiding these assets from the IRS, such as bringing money back to the United States in small increments, or by disguising money transfers as related to the sale of artwork or jewelry.
Prosecutors said Little helped in opening an undeclared Swiss account for the purpose of holding and hiding the widow’s inheritance funds and enlisted an accountant to prepare false and fraudulent tax returns and keep falsified accounting records for a corporate entity.
They also said Little failed to file any tax returns with the IRS between 2005 and 2010, despite earning hundreds of thousands of dollars of income as an attorney.
When he was arrested in 2012, Little was initially represented by Morvillo, Abramowitz, Grand, Iason & Anello. But three months later, the firm withdrew and Little began representing himself, with solo practitioner Sean Maher appointed as his standby counsel.
Little, a green card holder of the United States since 1972, was convicted on Tuesday of obstructing and impeding the due administration of the internal revenue laws, failing to file personal income tax returns, willfully failing to file reports of foreign bank and financial accounts, conspiracy to defraud the United States, and aiding and assisting the preparation of false tax returns.
Maher could not be reached for comment. Little, in an email message, declined to comment, other than to say he is “obtaining advice as to grounds of appeal.”
U.S. District Judge P. Kevin Castel of the Southern District of New York is scheduled to sentence Little on Sept. 6. Assistant U.S. Attorneys Christopher DiMase, Dina McLeod and Andrew Dember led the prosecution.