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IRS Investigation of Sloan Individually
In May 1991, Revenue Officer Lucille Sutton (Ms. Sutton) began
an investigation regarding Sloan's failure to file a 1987
individual return. During the course of this investigation, she
discovered that Sloan and/or his estate had wages and dividend
income in 1987 but no returns reporting such income had been filed.
On February 12, 1992, Ms. Sutton went to Baum’s office in
order to speak to David about his father. She was told that David
was out of the office. She left her business card, requesting
David to contact her. Because David failed to do so, Ms. Sutton
attempted to reach him by telephone on February 14, 1992. She was
told that David was in a meeting; again, she left a message
requesting David to return her call. David again failed to contact
her.
On February 19, 1992, Ms. Sutton again attempted to speak with
David by telephoning him at work. She was told that David was
attending a business luncheon. Ms. Sutton left a message with a
Baum employee, again requesting that David telephone her.
Despite Ms. Sutton’s leaving numerous messages for David at
Baum, David never contacted Ms. Sutton. Consequently, on March 20,
1992, she made another visit to Baum’s office. There, she spoke
with a Mr. Richardson, a Baum employee, who informed her that: (1)
David was out of town; (2) Sloan was deceased (although Mr.
Richardson did not know the date of death); and (3) Sloan was
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