- 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 investigationPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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