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On or about ___________ , in the ___________ District of ______, JOHN DOE, defendant herein, knowingly and fraudulently concealed the income tax records relating to the financial affairs of XYZ Company, which company was then in bankruptcy under Title 11, Case No. _______.
In violation of 18 U.S.C. § 152(8).
[cited in USAM 9-41.001]