T.C. Memo. 2000-216
UNITED STATES TAX COURT
CROP ASSOCIATES-1986, FREDERICK H. BEHRENS,
TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12532-90. Filed July 17, 2000.
P has moved for dismissal or alternative relief
based on respondent’s misconduct. Petitioner’s
principal complaints are:
1. A civil investigation was carried out in the
guise of a criminal investigation.
2. Conversations subject to the attorney-client
privilege were unlawfully monitored.
3. Documents were unlawfully seized pursuant to a
defective search warrant.
Petitioner requests that the case be dismissed, or
alternatively, that the Court shift the burden of going
forward with the evidence, and/or suppress evidence
illegally and improperly obtained by R.
Held: Petitioner has failed to prove his claims
of misconduct. The motion will be denied.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011