William Kale - Page 7

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               In January 1981, petitioner retired from the IRS.  Prior to            
          retiring, petitioner assured Toll that Suval would compromise the           
          1979 and 1980 audit.  Suval and Toll met in June 1981 to confirm            
          the $65,000 bribe.  Subsequently, Suval requested, and Toll                 
          agreed to pay, an additional $50,000, for a total of $115,000, to           
          ensure the favorable audit.  Petitioner was unaware of the                  
          additional $50,000 bribe.                                                   
          Payment of the $65,000 Bribe                                                
               Toll paid Suval the $115,000 in installments beginning in              
          the Autumn of 1981, and ending in 1983. Suval paid petitioner the           
          agreed upon $7,500 in installments as Suval received his payments           
          from Toll.                                                                  
          Criminal Investigation                                                      
               In early 1984, IRS inspectors confronted Suval with their              
          knowledge of Suval’s having receiving bribes.  Suval agreed to              
          cooperate with the U.S. Government by wearing a “body wire” in              
          conversations Suval had with petitioner in April 1984. Suval was            
          subsequently indicted for, and pleaded guilty to, bribery and               
          conspiracy to commit bribery, among other offenses.                         
               Concurrently, a criminal investigation of the Cynwyd Group’s           
          operations commenced in connection with their bribing IRS                   
          officials.  Toll was subsequently indicted for, and pleaded                 
          guilty to, bribery and conspiracy to commit bribery, among other            
          offenses.                                                                   
               On February 4, 1986, petitioner was indicted by the Federal            
          Grand Jury for and in the U.S. District Court for the Eastern               



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