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into the Royal Bank of Canada during these years. By 1989
petitioner had approximately $1 million deposited with the Royal
Bank of Canada and over $3 million in all Canadian accounts
combined.
After the initiation of the criminal investigation by the
IRS, petitioner removed business records from the East Gyn
Medical Clinic. Petitioner falsely told special agents on
August 23, 1990, that he never removed records indicating cash
payments received at the clinic. Petitioner instructed an
employee, Minnie Malone, that if anyone asked her about the
records to state that the State of Michigan took them during a
Medicaid audit.
During the April 18, 1990, interview of petitioner by
special agents, Dr. Kalo stated that records used to record cash
payments for the clinic had been seized by the State of Michigan
during a Medicaid audit and were never returned. In a subsequent
interview by special agents, petitioner stated that the records
had been returned by the State of Michigan. These records, along
with records from petitioner's other clinics, were summonsed by
Special Agent Kevin Boudreau. The summonses specifically
requested any records which reflected cash receipts. At no time
during the CID investigation did petitioner produce any record
reflecting the cash receipts received by the clinic for the years
1986 through 1989.
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