In November 1997, Max pleaded guilty in Manhattan federal district court to charges of concealing more than $1.1 million in income from the Internal Revenue Service in connection with the sales of his works between 1988 and 1991. The plea came two days before he was to go on trial on an 11-count conspiracy and tax fraud indictment. Under the deal, he pleaded guilty to a charge of conspiracy to defraud the IRS and a charge of tax evasion, telling a federal judge that he had taken payments in cash, deposited customers' checks into his personal account and arranged other transactions to avoid tax liability. In June 1998, he was sentenced to two months in prison and a $30,000 fine. The federal judge ordered Max to pay the taxes he owed and to perform 800 hours of community service.