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  "document_metadata": {
    "page_number": "21",
    "document_number": "A-5923",
    "date": null,
    "document_type": null,
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  "full_text": "CAC3PARC\n21\n1 So it's quite clear the jury was entitled to infer that he knew\n2 that this was being done to change the results of the tax\n3 losses. He also knew, and there is more than a plethora of\n4 evidence on this, that each of these tax shelter transactions\n5 had to be completed by year end. And that's why, as Mr. Bair\n6 testified and others testified, it was a real effort.\n7 Sandra Burnside, you might recall, Mr. Daugerdas'1\n8 secretary, testified about the avalanche of work that went on\n9 in December at the end of the tax years in order to finalize\n10 these transactions. Well, that avalanche of work hit the\n11 offices of Mr. Parse's desk. And as Carrie Yackee testified,\n12 Carrie Yackee's desk as well.\n13 So to suggest that he was not aware this was being\n14 done in order to defraud the IRS as the true results of the\n15 transaction we submit is unsupportable.\n16 There was a suggestion in Mr. Shechtman's brief, I\n17 don't think he touched on it today, but the suggestion was that\n18 these transactions, these as transactions were approved by\n19 Deutsche Bank.\n20 Well, first of all, Carrie Yackee's testimony here\n21 that she was going to Mr. Parse for approval on these\n22 transactions. There is also evidence to suggest that anyone\n23 other than Mr. Parse and Carrie Yackee at Deutsche Bank knew\n24 the full picture of what went on, which was that these\n25 transactions for these particular taxpayers were tax shelter\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010178",
  "text_blocks": [
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      "type": "printed",
      "content": "CAC3PARC",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 So it's quite clear the jury was entitled to infer that he knew\n2 that this was being done to change the results of the tax\n3 losses. He also knew, and there is more than a plethora of\n4 evidence on this, that each of these tax shelter transactions\n5 had to be completed by year end. And that's why, as Mr. Bair\n6 testified and others testified, it was a real effort.\n7 Sandra Burnside, you might recall, Mr. Daugerdas'1\n8 secretary, testified about the avalanche of work that went on\n9 in December at the end of the tax years in order to finalize\n10 these transactions. Well, that avalanche of work hit the\n11 offices of Mr. Parse's desk. And as Carrie Yackee testified,\n12 Carrie Yackee's desk as well.\n13 So to suggest that he was not aware this was being\n14 done in order to defraud the IRS as the true results of the\n15 transaction we submit is unsupportable.\n16 There was a suggestion in Mr. Shechtman's brief, I\n17 don't think he touched on it today, but the suggestion was that\n18 these transactions, these as transactions were approved by\n19 Deutsche Bank.\n20 Well, first of all, Carrie Yackee's testimony here\n21 that she was going to Mr. Parse for approval on these\n22 transactions. There is also evidence to suggest that anyone\n23 other than Mr. Parse and Carrie Yackee at Deutsche Bank knew\n24 the full picture of what went on, which was that these\n25 transactions for these particular taxpayers were tax shelter",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010178",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Bair",
      "Sandra Burnside",
      "Mr. Daugerdas",
      "Carrie Yackee",
      "Mr. Parse",
      "Mr. Shechtman"
    ],
    "organizations": [
      "Deutsche Bank",
      "IRS",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [],
    "reference_numbers": [
      "A-5923",
      "DOJ-OGR-00010178"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is clear and legible, with no visible redactions or damage."
}