COUNT FIFTY-EIGHT
1. Part A of Counts One through Twelve is hereby realleged as if fully set forth herein.
2. That between in or about March 1996 up to and including the dates of the return of this indictment, in the Northern District of Florida, the defendant,
KENT E. HOVIND,
did corruptly endeavor to obstruct and impede the due administration of the internal revenue laws by acts which include the following:
a. Filing a petition for bankruptcy, and falsely listing the IRS as his only creditor, for the sole purpose of discharging this debt and forcing the IRS to release seized property;
b. Filing a false and frivolous lawsuit against the IRS in which he demanded damages for criminal trespass and other false allegations during the IRS execution of a lawful court-issued search warrant;
c. Filing a complaint for a preliminary injunction against an investigation IRS special agent and the Commissioner of the IRS;
d. Making threats of harm to those investigating him and to those who may consider cooperating with their investigation;
e. Filing a false complaint against investigating IRS agents with the Treasury Inspector General for Tax Administration;
f. Filing a criminal complaint against investigating IRS special agents falsely alleging, among other things, false arrest, false imprisonment, excessive use of force, and theft or property;
g. Destroying records; and,
h. Paying his employees in cash and labeling them “missionaries” rather than employees to avoid payroll tax and Federal Insurance Contributions Act requirements.
All in violation of Title, United States Code, Section 7212(a).
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