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Niguel Examination Division). On June 16, 1988, Mr. Martin
ceased his investigation of AMCOR.
Examinations of AMCOR-Sponsored Partnerships
Beginning in 1987 and continuing through July 1988, Bobbie
Tadlock, then a revenue agent assigned to the Laguna Niguel
Examination Division, conducted a civil tax examination of the
income tax returns of certain AMCOR-sponsored partnerships (the
AMCOR partnerships examination). By a letter dated July 14,
1988, Mr. Tadlock informed AMCOR that respondent was considering
both penalties against AMCOR under section 6700 for promoting
abusive tax shelters and an injunction under section 7408 to
enjoin further promotion of such shelters.
Intermittently, from August 1988 to January 1990, the AMCOR
partnerships examination was continued by Debbie Gaither, then a
revenue agent also assigned to the Laguna Niguel Examination
Division. As part of her examination, Ms. Gaither requested
various documents relating to the AMCOR partnerships from AMCOR.
Commencing on or about October 17, 1988, and for a period of
about 2 weeks, Ms. Gaither visited the offices of AMCOR and made
copies of many documents.
On October 26, 1988, at the initiation of Mr. Tadlock, the
chief of the Laguna Niguel Examination Division referred AMCOR to
respondent’s CID for a criminal tax fraud investigation (the
fraud referral). AMCOR is described in the fraud referral as a
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