David Daniel and Annette Daniel - Page 3

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            taxpayers' returns or in determining taxpayers' tax liabilities.                             
            During the years at issue, Mrs. Daniel worked as a customer                                  
            service manager in the Collections Division in charge of                                     
            overseeing other account representatives.                                                    
                  Petitioners are active members of their local religious                                
            community.  They also support a missionary church in Jamaica that                            
            operates a basic (elementary) school for children.  Petitioners                              
            are friendly with the missionary church's minister and have                                  
            attended church functions with the minister and his wife.                                    
                  In early October 1992, several days of heavy rain caused a                             
            flood that damaged petitioners' property.  The flood caused water                            
            damage to a sunk-in family room and a garage located at the rear                             
            of their house.  The flood also destroyed several trees in                                   
            petitioners' backyard.                                                                       
                  Mrs. Daniel ordinarily fills out petitioners' tax returns.                             
            Since she was uncertain as to how to claim a casualty loss                                   
            deduction on their 1992 return for the flood damage, she asked                               
            Albert Rabassa, one of her subordinates in the Collections                                   
            Division, to assist her.                                                                     
                  Mr. Rabassa began his employment with the Internal Revenue                             
            Service (IRS) in September 1990.  In 1988 or 1989 (Mr. Rabassa's                             
            testimony was that he was not sure of the date), Mr. Rabassa was                             
            employed at Florida National Bank as a senior vice president.  He                            
            was 58 years old and was employed as Division Director of Data                               
            Processing; his salary was $99,000 per year.  He also enjoyed                                
            various "perks" and bonuses.  The bank was sold in 1988 or 1989                              



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