Jeffrey C. and Kelly O. Stone - Page 8

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               Petitioners contend that the sharing of information between            
          the Department of Revenue and respondent violated section 6103              
          because no written requests were made for petitioners' return               
          information.  We disagree.  The Implementation Agreement was                
          similar to the agreements in Taylor, Long, and Smith, and                   
          constitutes the required written request.                                   
               We conclude that the Implementation Agreement satisfied                
          section 6103(d) and that the sharing of information between the             
          Department of Revenue and respondent was not an unauthorized                
          disclosure.                                                                 
          2.   The Privacy Act                                                        
               Petitioners allege that on June 6, 1994, respondent raided             
          the offices of American Mutual Investment Co. in Billings,                  
          Montana.  Petitioners further allege that respondent took all of            
          the client files of Otis.  Petitioners allege that respondent               
          visited all of the Otis clients and asked for all of their tax              
          and trust materials.  Petitioners contend that they were audited            
          as a result of the raid and that the audit violated the Privacy             
















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