Dwight L. McKenna and Beverly S. McKenna - Page 26

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            Federal checking account.  Mr. Bruno did not know petitioner was                            
            cashing and exchanging checks until testimony was given before                              
            the grand jury on May 25, 1990.                                                             
                  Throughout the course of Ms. Davis' examination, petitioner                           
            never told Mr. Bruno that the income figures he gave to him for                             
            1987 and 1988 were incorrect.  Similarly, throughout the ensuing                            
            criminal investigation in which Mr. Bruno assisted in the                                   
            representation of petitioner, Mr. Bruno was never told that the                             
            income figures were incorrect.                                                              
                  Mr. Bruno subsequently furnished Ms. Davis with information                           
            which attempted to establish the nontaxable nature of $100,000 of                           
            the understatement.  Since the amount of $150,000 still remained                            
            unexplained, Ms. Davis determined that it represented unreported                            
            income.  She then explained that the Service likely would want to                           
            begin an examination of petitioners' 1988 income tax return.                                
            After consulting with her supervisor, Ms. Davis told Mr. Bruno                              
            that the subsequent year examination would be commenced.                                    
                  In March 1990, two attorneys, Mr. White and Mr. Gray,                                 
            representing petitioners with a valid power of attorney, went to                            
            Ms. Davis' office and requested that they meet with her and her                             
            manager.  Mr. White thought Ms. Davis had completed the                                     
            examination for both 1987 and 1988, although she had not begun                              
            the examination for 1988.  Although the then proposed deficiency                            
            for 1987 was approximately $50,000, Mr. White stated that                                   






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