Dwight L. McKenna and Beverly S. McKenna - Page 27

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            petitioners wanted to agree to the liability because it was                                 
            "pocket change".  Mr. White also expressed concern that the case                            
            would be referred to the Criminal Investigation Division.                                   
                  Shortly after the March 1990 meeting, Ms. Davis was advised                           
            to suspend her examination because petitioner had become the                                
            subject of a criminal investigation.                                                        
                  During her examination of petitioners' returns, Ms. Davis                             
            was not told that petitioner had an investment account with the                             
            brokerage firm of Howard, Weil, Labouisse Friedrichs, Inc., and                             
            she received no investment account information pertaining to that                           
            company.                                                                                    
                  During the examination petitioner did not tell Ms. Davis                              
            that he had cashed checks and had not deposited them into his                               
            checking account.                                                                           
                  During the examination petitioner did not tell Ms. Davis                              
            that he was going to First Federal and exchanging income checks                             
            he had received from personal injury attorneys for First Federal                            
            bank checks.                                                                                
            Petitioner's Criminal Conviction Under Section 7206(1).                                     
                  On September 19, 1991, petitioner was indicted by the Grand                           
            Jury for the United States District Court for the Eastern                                   
            District of Louisiana on two counts of violating section 7206(1)                            
            for the taxable years 1987 and 1988.  The indictment charged                                
            petitioner with making false statements on his Federal income tax                           






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