Leo N. Levitt and Ruth G. Levitt - Page 20

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               3.   Early Stages of the Investigation                                 
               Special Agent Erich Fried (Fried) was the first agent                  
          assigned to the investigation.  Revenue Agent Richard Cronin                
          (Cronin) was assigned to the investigation as the cooperating               
          agent.  He worked with Fried.  Irving B. Dubow (Dubow) supervised           
          the investigation.  Above Dubow in the chain of command were a              
          branch chief, an assistant division chief, and the Chief,                   
          Intelligence Division in Washington, D.C.  Dubow's agents                   
          believed that Ruth Levitt was related to an organized crime                 
               Fried started the file on this case when he received a                 
          newspaper clipping stating that the Union County prosecutor's               
          office had obtained an indictment of petitioner for chemical                
          theft.  Fried immediately began trying to get Resyn's books and             
          records.  Fried, Cronin, and Dubow wanted to calculate Resyn's              
          tax liability so the Commissioner could file a proof of claim in            
          the Resyn bankruptcy proceeding.  Fried and Cronin tried                    
          unsuccessfully to obtain Resyn's records from the bankruptcy                
          trustee and receiver.  At that time, Fried and Dubow did not use            
          the administrative summons procedure under section 7602 because             
          they believed it took too long to enforce.                                  
               4.   Reluctant Witness Procedure                                       
               During the years respondent investigated this case,                    
          respondent sometimes used the "reluctant witness" procedure to              
          obtain evidence.  Under this procedure, a special agent could               
          request IRS and Justice Department approval to subpoena a witness           

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Last modified: May 25, 2011