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hearing commenced on October 4, 1999, and ended on November 5,
1999.
AMCOR
AMCOR was organized in 1981 by petitioner, George Schreiber,
and Robert Wright.
As of December 1988, AMCOR was headquartered in Irvine,
California.
For a period beginning some time after AMCOR’s organization
in 1981 and ending in 1986, AMCOR was in the business of
promoting tax shelter partnerships, including the partnership.
General Partners
During 1986 and all subsequent years relevant to this case,
petitioner, George Schreiber, and Robert Wright were the only
general partners of the partnership. Mr. Schreiber died in
August 1991.
Respondent’s Examinations
Introduction
During the mid- and late-1980's, AMCOR’s business activities
drew the attention of various of respondent’s officers and
employees, particularly civil examination and criminal
investigative personnel in respondent’s Dallas, Texas, and Laguna
Niguel and San Jose, California, districts. Those personnel
examined and investigated both AMCOR and various entities and
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