-7-
large television sets). The informant told Voorhees that either
petitioner or Hickey had told the informant that petitioners kept
large amounts of cash in petitioner’s car. On the basis of this
information, Voorhees began a preliminary investigation of
petitioners to determine whether he should begin a formal
criminal investigation. Voorhees closed the preliminary
investigation on or about September 18, 1994, concluding that he
had insufficient information to support a criminal investigation
of petitioners. In connection with that closing, Voorhees
contacted Cox. Voorhees told Cox the information that Voorhees
had received from the confidential informant and told Cox that he
should consider looking into the ability of petitioner to pay his
delinquent Federal income taxes, as he may be financially able to
do so. At no time during that conversation, nor at any other
time, did Voorhees advise or direct Cox to do any specific work
as to petitioner from either a civil or criminal point of view.
On or about October 11, 1994, Cox reopened his collection
case as to petitioner’s delinquent Federal income tax liability.
Seventeen days later, Cox visited petitioner’s residence, a
two-story house that he and his ex-wife had built in 1976 for
$47,000, where Cox observed a fairly new Jeep Wrangler in the
driveway, a new Jacuzzi in the backyard, and a new front door.
Petitioner did not answer Cox’s knock at the door, and Cox left
his business card at the house without speaking either to
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