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individuals that either purchased equipment from PCCL or provided
goods and/or services to petitioners and PCCL. The revenue agent
also interviewed petitioners and former employees of PCCL. The
revenue agent also requested and obtained documents relevant to
the examination.
At some point the revenue agent made a referral to the
Criminal Investigation Division of the IRS (CID). Special agents
from CID interviewed petitioners on June 7 and June 15, 1995.
During the course of the interviews, petitioners discussed Paige
and his involvement with PCCL, as well as the improvements made
to their home, the unreported sales of PCCL equipment, and
Dorrial, Inc.
Throughout the examination and investigation, petitioners
maintained they were unaware PCCL paid for the improvements to
their home. They alleged that Paige made all arrangements for
the work to be completed. Notwithstanding the above, it was
discovered that petitioner Allaire had signed PCCL's checks in
order to pay for the home improvements. She claimed to have no
knowledge of the purpose of the checks. Additionally, respondent
was provided with specific invoices, memoranda, and a proposal
from Wayne Catalano and Al Horn, third-party contractors that
completed the improvements to petitioners' home. These
documents, in total, reflected that PCCL was billed in the amount
of $8,549 for work completed at petitioners' home.
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Last modified: May 25, 2011