Harvey M. Pert, Transferee - Page 8

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          D.   Mr. Riffe's Estate                                                     
               1.   Administration of Mr. Riffe's Estate                              
               Mr. Riffe died testate.  Mrs. Pert was the personal                    
          representative and sole beneficiary of Mr. Riffe's estate.                  
          Donald F. Kaltenbach (Kaltenbach) represented Mrs. Pert in her              
          capacity as personal representative of Mr. Riffe's estate.  He              
          had previously represented hundreds of personal representatives             
          of estates and was familiar with documents filed in probate                 
          proceedings.                                                                
               Early in the probate proceedings, Mrs. Pert and Kaltenbach             
          knew that respondent was investigating the tax liabilities of Mr.           
          Riffe and Mrs. Pert.  On February 28, 1991, Revenue Agent Joe               
          Elliott (Elliott) questioned Mrs. Pert about her assets, the                
          business operations of West Coast Pest Control and West Coast               
          Florida Pressure Cleaning, how she derived income from the                  
          businesses, and her cash on hand.  Mrs. Pert denied that she or             
          Mr. Riffe had a cash hoard or any large sums of cash on hand.               
          Mrs. Pert told Elliott that she had to borrow money from friends            
          and family because she had no funds and she had no signature                
          authority over any of the business bank accounts.  Kaltenbach was           
          present when Elliott interviewed Mrs. Pert on February 28, 1991.            
          On March 1, 1991, Elliott went to Mrs. Pert's residence to get              
          books and records to start an income tax audit.                             







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