UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA                       v. PETER ZANONE,                   Defendant.

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Criminal No.: 98 CR 379 Filed: 4/23/98 Violation: 26 U.S.C. § 7206(1) Judge Cote

FRAUD AND FALSE STATEMENTS
(26 U.S.C. § 7206(1))

The United States of America, acting through its attorneys, charges:

That on or about each of the filing dates set forth below, in the District of New Jersey, Peter Zanone ("Zanone"), a resident of Cresskill, New Jersey and, at the time of filings, Manager of Promotional Printing and Displays for Warner-Lambert Co., did unlawfully, willfully, and knowingly make and subscribe to U.S. Individual Income Tax Returns, Forms 1040, for calendar years 1989, 1990, 1991, 1992 and 1993, each of which was verified by his written declaration that it was made under penalties of perjury, and each of which he did not believe to be true and correct as to every material matter, in that, he and his wife failed to report approximately $5000 in cash as income in 1989 and approximately $10,000 in cash as income in each of the subsequent calendar years from 1990 through 1993 (a total of approximately $45,000) that he received from the president and owner of a supplier of display materials based in Manhattan to which he had awarded a significant number of contracts, as summarized below:

YEAR	FILING DATE	TAXABLE INCOME AS REPORTED	CORRECT TAXABLE INCOME
1989	4/14/90	$79,600	$84,600
1990	4/11/91	$71,600	$81,322
1991	4/14/92	$70,986	$80,986
1992	4/14/93	$75,159	$85,159
1993	4/15/94	$83,119	$93,119

IN VIOLATION OF TITLE 26, UNITED STATES CODE, SECTION 7206(1).

Dated:

_______________"/s/"________________ JOEL I. KLEIN Assistant Attorney General _______________"/s/"________________ GARY R. SPRATLING Deputy Assistant Attorney General _______________"/s/"________________ JOHN T. ORR Director of Criminal Enforcement Antitrust Division United States Department of Justice _______________"/s/"________________ MARY JO WHITE United States Attorney Southern District of New York

_______________"/s/"________________ RALPH T. GIORDANO Chief, New York Field Office _______________"/s/"________________ REBECCA MEIKLEJOHN _______________"/s/"________________ STEVEN TUGANDER Attorneys, Antitrust Division United States Department of Justice 26 Federal Plaza Room 3630 New York, New York 10278 (212) 264-0654