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After examining the county court records, Ms. Sutton
discovered that Sloan's estate was not probated. She also secured
a copy of Sloan's death certificate from the Bureau of Vital
Statistics.
On April 13, 1992, David appeared at Ms. Sutton's office, in
response to the summons. David gave her the following: Documents
concerning Sloan's medical and funeral expenses; a copy of an
estimated tax payment made with regard to Sloan's 1987 tax year;
and some 1987 monthly bank statements from Sloan's checking
account. Missing from these documents were Sloan's April and May
1987 checking account statements, as well as canceled checks drawn
from this account.
During this meeting, Ms. Sutton asked David whether he was a
trustee or executor of his father's estate. David replied that he
was unable to answer that question. He suggested that in order to
receive a response, the IRS should pose this question to Sloan's
wife (“Mrs. Allen”), who lives in Europe. David stated he did not
know “Mrs. Allen's” first name or address. Ms. Sutton then
requested further details regarding this “Mrs. Allen”. David
stated that in order for him to disclose details, a deposition
would be required. The meeting then concluded.
Later that day (April 13, 1992), David returned to Ms.
Sutton's office in order to retrieve the documents provided to her
earlier that day. At this second meeting, she informed David that
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