Padgett Coventry Price - Page 17

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          Ramos was unaware of alleged contemporaneous memoranda from                 
          petitioner to Mr. Reiter when he finalized his special agent’s              
          report.                                                                     
               IRS District Counsel reviewed the Criminal Investigation               
          Division’s recommendation to prosecute petitioner.  Allison                 
          Rodgers Haft was assigned to review petitioner’s case.  As part             
          of the review, petitioner was offered an opportunity to present             
          the IRS with defenses to the proposed criminal charges (criminal            
          conference).  At the criminal conference, held on October 18,               
          1995, Ms. Haft explained the proposed charges and offered                   
          petitioner the opportunity to present any defenses.                         
               Kenneth Gordon, a former IRS District Counsel attorney,                
          represented petitioner during the criminal investigation and at             
          the criminal conference.  After acknowledging that any statements           
          Mr. Gordon made could be used against petitioner in any                     
          subsequent legal proceedings, Mr. Gordon made a presentation of             
          petitioner’s defenses.  At the criminal conference, Mr. Gordon              
          did not assert that petitioner sent monthly memoranda to Mr.                
          Reiter regarding her Merrill Lynch account.  Mr. Gordon stated              
          that petitioner had absolutely nothing to do with her Merrill               
          Lynch account, and that she avoided mathematics, numbers, and               
          accounting for the law firm’s money.                                        
               In February 1996, Mr. Gordon sent the U.S. Department of               
          Justice attorney reviewing petitioner’s case copies of what                 






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