he Rev. Sun Myung Moon, the South Korean businessman who heads the controversial Unification Church, was indicted by a federal grand jury here today on charges of filing false income tax returns in the years 1973 though 1975.

The 12-count indictment also charges Moon and a close associate, Takeru Kamiyama, with conspiring to defraud the government on tax matters. The case was brought by the U.S. attorney's office for the southern district of New York.

Moon's attorney, Charles A. Stillman, called the charges "wholly without merit."

Andrew M. Lawler, an attorney for Kamiyama, declared, "We intend to enter a plea of not guilty to all of the charges."

At a press conference at Unification Church headquarters here, Dr. Mose Durst, president of the church's American branch, said Moon was out of the country.

"I have tried for three hours to find him and have made calls all over the world," he said.

Durst called the indictment a "kind of assassination" of Moon, who he said could not get a fair trial in this country because his religious beliefs.

The indictment says that for three years Moon and others deposited $1.6 million in a Chase Manhattan Bank account in Moon's name. Moon used the money for personal and business purposes, the indictment says, and he failed to report $112,000 of interest income from the account to the Internal Revenue Service.

Durst said the $1.6 million was from the church's Japanese and Korean branches. "The account should have been in the church's name," he said.

But Durst claimed Moon, who first came to the United States in 1972, did not understand U.S. tax laws and was getting his advice from a Japanese financial adviser who didn't speak English.

The indictment further alleges that Moon and Kamiyama in 1973 formed a profit-making company called Tong II Enterprises Inc. to import ginseng tea and other merchandise from South Korea to this country. Moon and his wife allegedly got $70,000 of stock in the company. The stock was in partial payment for merchandise bought on letters of credit by the Unification Church, according to the indictment. The stock was part of Moon's income and he was required by law to report it on his tax returns, the indictment says.

The indictment charges Moon with one count of conspiracy and three of filing false tax returns. If convicted, he could face up to 13 years in prison and fines totaling $25,000.

In addition to one count of conspiracy and two of aiding in the filing of false tax returns, Kamiyama is charged with a count each of obstructing the government's investigation and submitting false documents as well as four counts of perjury. If convicted on all nine counts, Kamiyama could face up to 41 years in prison and $75,000 in fines.

According to the indictment, Kamaiyama, 39, sought to impede the federal investigation by giving false testimony to the grand jury and submitting false documents to the Justice Department, among other things.

The anti-communist Moon, 61, who says he is acting under the direction of Jesus Christ, has been under almost continuous investigation since he brought his church to this country.

The church claims three million members in 137 countries.