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individuals with a connection to AMCOR. The following are
pertinent aspects of those examinations and investigations.
Investigation of Paul Hays
In May 1988, George Martin was a special agent working in
respondent’s Criminal Investigation Division (CID) and assigned
to respondent’s Dallas, Texas, district, with post of duty in
Amarillo, Texas. In May 1988, Mr. Martin was assigned the case
of Paul Hays, a farmer, who, acting through his attorney, Wendell
Davies, had approached the Internal Revenue Service with
information to disclose concerning a tax shelter scheme in which
Mr. Hays and several other farmers had participated. Mr. Martin
investigated Mr. Hays’ information, and that information led him
to AMCOR and certain employees and agents of AMCOR. On June 6
and June 14, 1988, with the consent of Mr. Hays and Steve
Sterquell, an accountant employed by Mr. Hays, Mr. Martin
monitored and recorded conversations concerning AMCOR among Ted
Frame, an attorney representing AMCOR, and Messrs. Hays,
Sterquell, and Schreiber. Mr. Martin came to suspect that AMCOR
was operating an “illegal tax shelter” and that others, including
Mr. Frame, had committed crimes in connection therewith. On
June 6, 1988, Mr. Martin learned that a civil examination of
AMCOR had been undertaken by personnel assigned to respondent’s
Examination Division in Laguna Niguel, California (the Laguna
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