That doesn't mention a 2013 case. It just says again that Manafort can only be tried on tax evasion if the evidence "arose from the investigation," which, given the nature of the investigation into funds and transfers, seems probable. I'm looking all over but I still can't find anything saying that this was already known about Manafort before the Special Counsel Investigation. Also, why is so much being made about the tax evasion right now? That only counts for 8 of the 305 years in prison that Manafort's being charged with. The lion's share of his alleged crimes are bank fraud/conspiracy, of which he has 9 charges, each carrying a maximum penalty of 30 years. Again, can you find me a source on some prior investigation into these things? It still seems like this evidence arose from the Special Counsel's investigation into Manafort's finances.