Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 1

                                 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.                             

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