SAN FRANCISCO (CBS SF) — The Department of Justice announced Thursday that it indicted software tycoon Robert Brockman on charges that he evaded paying $2 billion in taxes, making it the largest tax fraud case in U.S. history.

U.S. Attorney David Anderson for the Northern District of California discussed the charges against the 79-year-old billionaire at a press conference in San Francisco. Anderson said that Brockman used a family charitable trust in Bermuda and other offshore accounts to hide his finances for 20 years.

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The indictment contains 39 counts, including wire fraud, evidence tampering and destruction of evidence.

Helping the DOJ in the case is billionaire Robert Smith, CEO of Vista Equity Partners, who recently settled a tax crime case for $140 million. Smith, considered the richest Black man in America, started Vista Equity Partners with an investment from Brockman.

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“Complexity will not hide crime from law enforcement. Sophistication is not a defense to federal criminal charges,” said David L. Anderson, U.S. attorney for the Northern District of California. “We will not hesitate to prosecute the smartest guys in the room.

The indictment was unsealed Thursday and Brockman is scheduled to make an appearance in San Francisco.

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