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IRS Investigation of Sloan’s Estate’s Tax Liabilities
Thomas M. McGuire, Jr., an IRS estate and gift tax attorney,
was assigned to examine Sloan's estate. By letter dated May 31,
1994, Mr. McGuire requested David to appear at his office on June
23, 1994, with specific information set out in the letter. David
failed to appear.
Four days later, David telephoned Mr. McGuire to discuss the
May 31, 1994, letter. David explained that he had injured his back
and was in the eastern part of the United States. Mr. McGuire
asked David for his current address or telephone number; David
refused. Mr. McGuire then asked David to reply in writing to his
May 31, 1994, letter. Again, David refused to do so. Next, Mr.
McGuire asked David if his father owned publicly traded stocks;
David claimed to be unaware of any such stocks.
As this telephone conversation continued, David informed Mr.
McGuire that there were 1,184 shares of Baum stock outstanding and
that there was a “Mrs. Allen”, his father’s second wife, who lived
in France and had access to Sloan's financial records, wills,
codicils, and trust instruments. David stated that he had no
information about “Mrs. Allen”.
By letter dated July 1, 1994, Mr. McGuire advised David that
because he had not sent the previously requested records, David
would have to appear at his office on July 15, 1994, with the
requested documents. David failed to appear on that date.
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