8
Petitioners contend that the sharing of information between
the Department of Revenue and respondent violated section 6103
because no written requests were made for petitioners' return
information. We disagree. The Implementation Agreement was
similar to the agreements in Taylor, Long, and Smith, and
constitutes the required written request.
We conclude that the Implementation Agreement satisfied
section 6103(d) and that the sharing of information between the
Department of Revenue and respondent was not an unauthorized
disclosure.
2. The Privacy Act
Petitioners allege that on June 6, 1994, respondent raided
the offices of American Mutual Investment Co. in Billings,
Montana. Petitioners further allege that respondent took all of
the client files of Otis. Petitioners allege that respondent
visited all of the Otis clients and asked for all of their tax
and trust materials. Petitioners contend that they were audited
as a result of the raid and that the audit violated the Privacy
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