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In December 1970, petitioner filed a Statement of Affairs
with the bankruptcy court on behalf of Resyn, in which he
answered certain questions. Question 7 was as follows:
Bank accounts and safe deposit boxes
a. What bank accounts have you maintained,
alone or together with any other person and in your
name or any other name, within the two years
immediately preceding the filing of the original
petition herein?
(Give the name and address of each bank, the name
in which the deposit was maintained and the name of
every person authorized to make withdrawals from such
account.)
Petitioner answered question 7, but did not mention the Chemical
Traders or Polymer accounts.
The Commissioner filed a proof of claim on January 5, 1971,
and several amended proofs of claim between January 27, 1971, and
September 19, 1976. The Commissioner filed a final amended claim
of $2,376,726.43 for unpaid corporate income taxes, interest, and
penalties for 1963 to 1970.
F. Respondent's Investigation of Petitioner and Resyn
1. Administrative Investigation
Respondent began a joint criminal and civil administrative
investigation of petitioner and Resyn in December 1970. An
administrative investigation is an investigation that is
conducted solely by respondent's agents. It is not conducted
before a grand jury. A special agent and cooperating revenue
agents were assigned to the investigation.
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