- 32 -
mately one week thereafter, George D. Coupounas (Mr. Coupounas)
telephoned Mr. Kaply to advise him that on February 22, 1990,
petitioners had executed Forms 2848 authorizing Mr. Coupounas to
represent petitioners not only with respect to their taxable year
1987 that was being examined by Mr. Kaply, but also with respect
to their taxable years 1986 and 1988, and those forms were sent
to Mr. Kaply.
On April 24, 1990, Mr. Kaply and Norman Murphy (Mr. Murphy),
who was Mr. Kaply's acting manager, met (April 1990 meeting) with
Mr. Coupounas about petitioners' returns for 1987 and 1988 that
were being examined. At that meeting, Mr. Kaply asked Mr.
Coupounas questions about the Indian Head business savings
account and two of the accounts at Kennebunk, which were similar
to the questions that he had asked Mr. Dennett at the February
1990 meeting. Mr. Coupounas informed Mr. Kaply and Mr. Murphy at
the April 1990 meeting that he would answer Mr. Kaply's questions
only if Mr. Murphy promised not to refer petitioners' case to
respondent's Criminal Investigation Division (CID). When Mr.
Murphy declined to make any such promise, Mr. Coupounas indicated
that he was terminating the April 1990 meeting.
Shortly after the April 1990 meeting, Mr. Kaply turned
petitioners' audit over to CID, and that division began to
investigate not only petitioners' taxable years 1987 and 1988,
but also their taxable year 1986. Respondent's special agent,
Don Cote (Mr. Cote), was assigned to the criminal investigation
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