- 11 -
1993, Revenue Agent Rigney received information that petitioner
allegedly had unreported income from an antique automobile sale
in 1987. At this time, Revenue Agent Rigney believed that a re-
referral of petitioner's case to respondent's Criminal
Investigation Division (CID) was necessary, because there
appeared to be a 2-year pattern of omitted income on petitioner's
part. Respondent conducted a second criminal investigation from
October 1993 to April 1994, which also did not result in a
recommendation of criminal prosecution.
In September 1991, petitioner auctioned off a substantial
portion of his antique car collection and donated approximately
$4 million in proceeds to the Harvard Medical School, which
established a scholarship trust fund. Petitioner reserved a
lifetime income equal to 5 percent of the face value of the
trust.
OPINION
Before reaching the substantive issues in this case, we must
dispose of two preliminary issues raised by petitioner. First,
petitioner argues that Revenue Agent Rigney fraudulently induced
him into signing a Form 872 on February 16, 1993, extending the
period of limitations. Petitioner alleges that Revenue Agent
Rigney induced Mr. Asselin to get petitioner to sign the Form 872
with false representations that an extension was necessary to
conclude respondent's civil investigation. Petitioner contends
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