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Federal income tax returns and preparing Revenue Agent’s Reports
(RAR's), reflecting proposed changes to taxpayers’ examined
returns.
Examinations determine whether a taxpayer is due a refund,
owes additional taxes, or correctly reported his tax liability.
If no adjustments are made in an examination, a taxpayer receives
a clearance letter indicating that the return was accepted as
filed and the examination is closed. If adjustments are made,
RAR’s are then sent to the taxpayer, who, if in agreement with
the adjustments, signs the RAR. After signing the RAR, it is
forwarded to an IRS review department, which reviews the RAR and,
upon accepting the RAR’s findings, issues a clearance letter to
the taxpayer, closing the examination.
From at least 1979, petitioner was assigned to examination
group 1201, elevated to a Grade 13, the most senior revenue agent
position below management, and was responsible for examining the
most complex cases.
Charles Toll
Sometime in the early 1960's, petitioner examined the tax
returns of Colonial Beef Company. Needleman & Toll (Needleman)
was the accounting firm that handled Colonial Beef’s tax returns
and tax audits. Charles Toll (Toll) was an accountant at
Needleman until 1966. During the years he worked at the firm,
Toll was aware that Needleman was negotiating or paying bribes to
IRS agents in order to receive favorable IRS examination results.
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Last modified: May 25, 2011