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and Quinn drove these Lincoln Continental automobiles. Mr. Quinn
paid the automobile leases and insurance from the West Pine
checking account. John McCullough had asked Mr. Quinn to put
Messrs. Crosley and Walsh on the payroll and to pay the other
expenses as a favor to him for having found the investors. Once
or twice, Mr. Quinn wrote a West Pine check to Mr. Conwell to
cover the latter's personal telephone bill. Substantial amounts
of personal or nonbusiness expenses were paid out of the West
Pine checking account.
West Pine regularly was delinquent in the payment of its
quarterly Federal employment taxes. Beginning in March or April
of 1980 until November of 1981, Mr. Clark was the revenue office
responsible for monitoring West Pine's Federal employment tax
deposits. When West Pine's employment tax returns were late, Mr.
Clark would regularly summons the records necessary to prepare
those returns. Mr. Clark met with Mr. Quinn on numerous
occasions to prepare West Pine's employment tax returns.
In early 1982, IRS revenue officer John Higgins (Mr.
Higgins) took over the West Pine account. On September 9, 1982,
Mr. Higgins interviewed Mr. Quinn with regard to the 100-percent
penalty for West Pine's employment taxes. During that interview,
Mr. Quinn indicated that the officers of West Pine had been:
Mrs. Gaskins, president, 1975 to 1979; Oscar Glassman,
president, 1979 to June or July 1982; Mr. Quinn, secretary, 1975
to June or July 1982; and Joseph Crosley, vice president, 1979
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