Eloise Gaddy Joens - Page 7

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            residence.  Upon execution of the warrant, Special Agents for the                         
            IRS found no financial records pertaining to Emmens and                                   
            petitioner.  At that time, Emmens was in Federal custody and                              
            access to the residence was under petitioner's control.                                   
            Petitioner had removed many items from the residence, including a                         
            file cabinet containing financial records.  Special Agents also                           
            found a floor safe in the residence that was open and empty.                              
                  Thereafter, the tax investigation, which proceeded                                  
            separately from the narcotics investigation, was expanded to                              
            include petitioner and Kadyszewski, in addition to Emmens.                                
            Petitioner and Emmens were subsequently indicted for tax evasion                          
            under section 7201 for 1982, 1983, and 1984.  Kadyszewski was                             
            indicted for conspiracy.  Emmens pleaded guilty to tax evasion                            
            for 1984.  The terms of the plea agreement included the dismissal                         
            of the criminal tax case against petitioner and the dismissal of                          
            the remaining criminal tax counts against Emmens.  Kadyszewski                            
            subsequently went to trial and was convicted for conspiracy to                            
            defraud the United States.                                                                
            Real Estate                                                                               
                  Prior to her marriage to Emmens, petitioner owned a                                 
            residence on Flamango Lakes Drive3 in West Palm Beach, Florida                            
            (the Flamango Lakes property or the property).  Petitioner and                            

                  3                                                                                   
                        In light of some confusion at trial, we note that                             
            petitioner owned a residence on "Flamango Lakes Drive", and not                           
            "Flamingo Lakes Drive."                                                                   




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