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had, whether they kept cash at home or at their business, and
whether they carried a significant amount of cash. Mrs. Spear
said they did not keep cash at home or at the business, and that
they did not carry cash. In January 1978, McGuckin recommended
that the decedent and Mrs. Spear be prosecuted for criminal
fraud.
Special Agent Lawrence Trepple (Trepple) conducted a
criminal investigation of the decedent and Mrs. Spear. He
examined their tax returns, bank accounts, financial statements,
and records that were filed at courthouses. He interviewed
Adrienne Wolf, the decedent's and Mrs. Spear's bookkeeper. He
reviewed the revenue agents' work and discussed matters with
them. Trepple interviewed the decedent and Mrs. Spear on March
13, 1978.
Trepple found that: (1) The value of the decedent and Mrs.
Spear's assets had increased substantially during the years in
issue, (2) the decedent and Mrs. Spear destroyed their records of
cash receipts, (3) the decedent and Mrs. Spear reported different
amounts of income on their Philadelphia parking lot tax returns
and Federal income tax returns, and (4) the decedent and Mrs.
Spear used corporate funds for their personal benefit without
reporting them as income. He did a net worth analysis and
appropriately investigated leads for nontaxable sources of
income. He learned that the decedent and Mrs. Spear's net worth
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