DAVIDB.BARLOW, United States Attorney (No. 13117) lUlZ ttlMi 114 ,6..

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ANNA M. PUGSLEY, Special Assistant United States Attorney (Provisionally A,4witted)
Attorneys for the United States of America DiS , 'v 1/\,1
185 South State Street, Suite 300
Salt Lake City, Utah 84111
Telephone: (801) 524-5682

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH, NORTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
vs.
ROBERT R. WATSON and
MARIE M. WATSON,
Defendants.
Case No.
INDICTMENT
VIO. 18 U.S.C. 371
Conspiracy
26 U.S.C. 7206(1)
Making and Subscribing to a
False Return
Case: 1:12-cr-00012
Assigned To : Waddoups, Clark
Assign. Date: 03/14/2012
Description: USA v.
The Grand Jury charges:
COUNT 1
18 U.S.C. 371
Conspiracy
Parties, Persons, and Entities
At all relevant times,
Case 1:12-cr-00012-CW Document 1 Filed 03/14/12 Page 1 of 7
1. Teazers Sports Bar & Grill (Teazers) was a corporation registered in the
state of Utah. It was a sports and entertainment club licensed to serve alcohol in Ogden,
Utah.
2. The Drink, Inc. was a corporation registered in the state of Utah and acting
as an S-Corporation. The Drink, Inc. owned the building and equipment of Teazers and
the land on which it was located.
3. Defendant ROBERT R. WATSON, age 52, of Pleasant View, Utah, was
president and general manager of Teazers.
4. Defendant MARIE M. WATSON, age 51, of Pleasant View, Utah, kept the.
books and records of Teazers. Defendants ROBERT R. WATSON and MARIE M.
WATSON were the sole owners and shareholders of The Drink, Inc.
5. The Internal Revenue Service (IRS) was an agency of the United States
Department of the Treasury, responsible for administering and enforcing the tax laws of
the United States.
The Conspiracy
6. From on or about January 1, 2004, the exact date being unknown to the
Grand Jury, and continuing thereafter up to and including at least December 31, 2009, in
the Northern Division of the District of Utah and elsewhere,
ROBERT R. WATSON and
MARIE M. WATSON,
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defendants herein, did unlawfully, voluntarily, intentionally, and knowingly conspire,
combine, confederate, and agree together and with each other to defraud the United States
for the purpose of impeding, impairing, obstructing, and defeating the lawful Government
functions of the Internal Revenue Service of the Treasury Department in the
ascertainment, computation, assessment, and collection of the revenue: to wit, income
taxes.
Manner and Means of tbe Conspiracy
7. It was a part of the conspiracy that defendants MARIE M. WATSON and
ROBERT R. WATSON caused substantial cash receipts from Teazers not to be recorded
on any ofthe books and records of the company.
8. It was further a part of the conspiracy that defendants ROBERT R.
WATSON and MARIE M. WATSON prepared financial records for Teazers knowing
that substantial cash receipts from Teazers were not included therein.
9. It was further a part of their conspiracy that defendants ROBERT R.
WATSON and MARIE M. WATSON delivered to their tax preparer financial records
that did not include substantial cash receipts from Teazers, knowing that these records
were false and misleading.
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10. It was further a part of the conspiracy that defendants ROBERT R.
WATSON and MARJE M. WATSON used cash receipts from Teazers to pay personal
expenses and did not report this information to their tax preparer or to the IRS.
Overt Acts
In furtherance of the and to effect the objects thereof, the following
acts were committed in the Northern Division of the District and elsewhere:
11. On or about the dates shown below, ROBERT R. WATSON and MARJE
M. WATSON prepared and caused to be prepared, signed, and filed with the IRS tax
returns for the taxyears shown below which were false and fraudulent.
Date Filed Tax Year Form
March 15,2005 2004 Corporation Income Tax Return (Form 1120)
March 15,2006 2005 Corporation Income Tax Return (Form 1120)
March 16, 2007 2006 Corporation Income Tax Return (Form 1120)
March 28, 2008 2007 Corporation Income Tax Return (Form 1120)
March 15,2009 2008 Corporation Income Tax Return (Form 1120)
April 15, 2005 2004 Joint Individual Income Tax Return (Form 1040)
April 15, 2006 2005 Joint Individual Income Tax Return (Form 1040)
April 15,2007 2006 Joint Individual Income Tax Return (Form 1040)
April 16, 2008 2007 Joint Individual Income Tax Return (Form 1040)
April 17, 2009 2008 Joint Individual Income Tax Return (Form 1040)
All in violation of 18 U.S.C. 371.
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COUNTS 2-5
26 U.S.C. 7206(1)
Making and Subscribing to a False Return
12. On or about the dates shown below, in the Northern Division of the District
of Utah and elsewhere,
ROBERTR. WATSON,
a resident of Pleasant View, Utah, did willfully make and subscribe United States
Corporation Income Tax Returns (Form 1120), for Teazers for the tax years 2005-2008,
which were verified by written declarations that they were made under the penalties of
perjury and which he did not believe to be true and correct as to every material matter.
Those income tax returns, which were prepared and signed in the District of Utah and
were filed with the Internal Revenue Service, reported on Line 11 (Total Income) the
amounts shown below, whereas, as he then and there well knew and believed, these line
items were false because the tax returns failed to report material additional gross receipts
received by Teazers during each respective tax year.
Count Date Filed Tax Year Total Income
2 March 15,2006 2005 $846,166
3 March 16,2007 2006 $865,371
4 March 28, 2008 2007 $807,350
5 March 15,2009 2008 $842,804
All in violation of26 U.S.C. 7206(1).
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COUNTS 6-9
26 U.S.C. 7206(1)
Making and Subscribing to a False Return
13. On or about the dates shown below, in the Northern Division of the District
of Utah elsewhere,
ROBERT R. WATSON and
MARlEM. WATSON,
defendants herein, did willfully make and subscribe joint U.S. Individual Income Tax
Returns (Form 1040), for the tax years 2005-2008, which were verified by a written
declaration that they were made under the penalties of perjury and which the defendants
did not believe to be true and correct as to every material matter. Those income tax
returns, which were prepared and signed in the District of Utah and were filed with the
Internal Revenue Service, reported on Line 37 (Adjusted Gross Income) the amounts
shown below, whereas, as the defendants then and there well knew and believed, these
line items were false because the tax returns failed to report material additional income
received by the defendants during each respective tax year.
Count Date Filed Tax Year Adjusted Gross Income
6 April 15, 2006 2005 $42,086
7 April 15, 2007 2006 $70,114
8 April 15, 2008 2007 $90,952
9 Apri115,2009 2008 $77,584
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All in violation of26 U.S.C. 7206(1).
A TRUE BILL:
10\
FOREPERSON OF THE GRAND JURY
DAVID B. BARLOW
United States Attorney
ANNA M. PUGSLEY
Special Assistant United States Attorney
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