- 12 - find no such conduct in the instant case. Although it is not standard practice in the Border Patrol to ask people who are carrying large amounts of currency questions about tax returns, Reese explained that he asked petitioner tax questions to determine whether petitioner had a legitimate source for his income. Reese's questions about petitioner's tax returns in the circumstances of this case do not indicate that tax violations were in his zone of primary interest. Agreement Between Agencies Petitioner contends that an agreement to share information between agencies in this case mandates application of the exclusionary rule. Courts frequently examine whether agreements exist between agencies, to determine whether suppressing evidence illegally obtained by one agency and offered by another will deter future unlawful searches and seizures. Grimes v. Commissioner, supra at 290; Wolf v. Commissioner, supra at 195; Tirado v. Commissioner, supra at 314-315; Guzzetta v. Commissioner, 78 T.C. 173, 180-182 (1982); Black Forge, Inc. v. Commissioner, supra at 1011. Although generally recognizing that such agreements increase the likelihood that deterrence will be achieved by applying the exclusionary rule, courts have considered a variety of elements in determining whether thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011