William Kale - Page 6

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          review department.  Suval had been employed by the IRS for over             
          30 years.  Petitioner was aware that Suval had received bribes in           
          the past in order to compromise audits.  In early 1980,                     
          petitioner approached Suval, confided to him that he, petitioner,           
          was going to receive bribe payments from Toll for favorably                 
          auditing the 1977 and 1978 Cynwyd Group returns, and offered                
          Suval $6,500 to expedite the processing through the review                  
          department of certain of the Cynwyd Group returns which                     
          petitioner examined.                                                        
          Payment of $105,000                                                         
               Toll paid petitioner the $105,000 bribe in five installments           
          beginning in August 1980 and ending November 1980.                          
          Toll’s Bribe to Suval                                                       
               Sometime in 1980, before the Cynwyd Group’s 1977 and 1978              
          returns were cleared, Toll requested petitioner to extend his               
          examination to include the Cynwyd Group’s 1979 and 1980 tax                 
          returns.  An Examination Division policy precluded petitioner               
          from examining the 1979 and 1980 returns.  Petitioner, however,             
          was able to ensure that the returns would be examined by group              
          1201, petitioner’s examination group.  In September 1980, Suval             
          became group 1201's examination manager.  Petitioner informed               
          Suval that he arranged for the Cynwyd Group’s 1979 and 1980                 
          returns to be examined by group 1201 and that Toll would pay                
          Suval $65,000 to compromise the audit.  Suval and petitioner                
          agreed that Suval would pay petitioner $7,500 for setting up the            
          $65,000 bribe.                                                              



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