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decorator. However, in a letter dated June 10, 1991, from Mr.
Kazanjian's accountant, Revenue Officer Lepkojus was informed that
the $124,000 was not for services rendered, but rather for
petitioner's share in a real estate venture which was sold in 1987.
In March 1991, Revenue Officer Lepkojus spoke with Dr. John
Williams, petitioner's former husband, who stated that he had paid
petitioner alimony during the years in issue.
In September 1991, Revenue Officer Lepkojus issued a summons
for petitioner's bank records, and in October 1991 he received the
records which included checks in large amounts.
On December 16, 1991, Revenue Officer Lepkojus obtained
information relating to petitioner's residence in Los Angeles,
California, and subsequently confirmed that address. Petitioner
was not present when he visited the home on January 29, 1992.
Revenue Officer Lepkojus referred petitioner's case to the
U.S. Department of Justice, Criminal Investigation Division (CID).
The case was returned to him in November 1992, and shortly
thereafter he forwarded it to the IRS examination division.
Examination by Revenue Agent Kropp
Revenue Agent David Kropp conducted an examination of
petitioner for her unpaid Federal income taxes for 1987, 1988, and
1989. His investigation took place from approximately May 22,
1995, to October 10, 1995.
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