- 26 - Posner obtained a blanket rule 6(e) order which he believed allowed him to give any information, books, or records to any Federal law enforcement officer. He did not get a rule 6(e) order for each investigation. Instead, he got one that covered all investigations of a grand jury which was usually good for about a year and a half. On April 4, 1974, O'Byrne testified before the grand jury that indicted petitioner under section 7201 for willful tax evasion for 1967 to 1969. J. Petitioner's Criminal Case In 1974, petitioner pleaded nolo contendere to tax evasion for 1970 and received a suspended sentence. K. Resyn's Bankruptcy Trial In January 1978, Resyn asked the bankruptcy court to expunge, reduce, or modify the Commissioner's corporate tax claim for 1963 to 1967 and fraud penalties for 1963 to 1969. The bankruptcy court held a 6-day trial in February and March 1981, during which the parties vigorously contested Resyn's tax liability. Zuckerman, one of petitioners' attorneys in the instant case, was Resyn's attorney at the trial. Zuckerman saw no conflict in representing petitioner and Resyn in the bankruptcy case. Petitioner attended the Resyn bankruptcy trial but did not testify. The bankruptcy court issued its opinion on November 18, 1981. That court decided that petitioner diverted Resyn incomePage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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