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While handling the Colonial Beef examination, Toll paid a bribe
to petitioner in order to receive favorable examination results.
Cynwyd
While at Needleman, Toll was responsible for the Saligman
and Cravitz families’ tax returns and tax audits. These families
held interests in numerous partnerships. Toll was also
responsible for representing those families with respect to the
tax returns and tax audits of these partnerships. The managing
general partners of these partnerships were three partnerships:
Saligman Special, Saligman Capital, and Cynwyd Investments.
Cynwyd Investments was primarily owned by members of the Saligman
and Cravitz families. By 1977, Toll also held an interest in
Cynwyd Investments. Hereinafter, references to the Cynwyd Group,
will refer to the various partnerships and entities owned
directly or indirectly by the Cravitz and Saligman families.
Toll was aware that the Saligman and Cravitz families,
through Needleman, were paying bribes to various IRS agents in
order to receive favorable audit results. In 1966, Toll was
hired by the Saligman and Cravitz families to oversee all of the
Cynwyd Group’s accounting, taxes, and finances. Toll remained at
that position until 1984, when a criminal investigation of the
Cynwyd Group commenced.
Petitioner’s Cynwyd Examinations
Sometime between October 1978 and April 1979, petitioner was
assigned the examination of the 1977 tax return of the Rita
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