- 7 - Sometime during or before 1984, the IRS initiated an investigation of ASI. As part of that investigation, an IRS special agent (Balash) examined petitioner's returns for the taxable years at issue. Balash met with Tubre on at least two occasions during the course of her investigation. On one occasion, Tubre informed Balash that petitioner "serviced" various accounts for Besco and that Besco’s payments to petitioner resulted from such service.4 This information was false, and Tubre knew of its falsity at the time he told it to Balash. On December 20, 1984, Balash met with petitioner. During the course of that meeting, petitioner represented to Balash that the income he received from Besco was in exchange for services he had provided Besco in the form of soliciting business or providing leads. In making such representations, petitioner referred to several of Besco’s customers and indicated that he had made contact with certain individuals within those organizations in his efforts to market Besco's products. As noted earlier, petitioner reported the income he received from Besco on his tax return for each taxable year at issue. 4It is not clear from the record what activities were involved in the alleged "servicing" by petitioner. The arguments advanced by both parties, however, suggest that such activities entailed providing leads to and soliciting business on behalf of Besco.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011