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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
racketeer.
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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