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Thereafter, Gibb was assigned to investigate Coral and Campbell
for violating sections 6700 and 6701.
An injunction case was filed by the Government against
Campbell on April 2, 1984, in the United States District Court,
Northern District of Texas, Dallas Division (District Court).
Gibb was assigned to assist the Department of Justice attorneys
with the Campbell case.
In response to interrogatories in the Campbell case, a list
of all U.S. entities contracting with Coral (the project list)
was filed with the District Court on January 14, 1987. The
project list did not contain taxpayer identification numbers,
addresses, or individuals involved in any of the listed entities
that had entered into contracts with Coral or the year that such
contracts were entered. Spencer Medical's 1983 contract is
reflected as client number "89 Spencer Medical Associates".
The project list was first located by Gibb in February 1987.
Of the 172 contracts on the project list, approximately 125 had
been identified prior to the location of the list. Prior to the
discovery of the project list, Spencer Medical had not been
identified by the IRS as one of the entities contracting with
Coral.
Partnership adjustments attributable to contracts entered
into by other entities, unrelated to Spencer Medical, with Coral
in 1982 were litigated in Agro Science Co. v. Commissioner, T.C.
Memo. 1989-687, affd. 934 F.2d 573 (5th Cir. 1991). Spencer
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