- 13 - promoter of abusive tax shelters. Its transactions are described as “shams”, generating “about $400,000,000 in first year tax deductions from 1981 through 1986, claimed on one hundred plus partnerships [returns].” The fraud referral accuses AMCOR of entering into purported farming transactions in which, among other things, crops were not grown and AMCOR and farmers drew and exchanged checks with neither party having sufficient funds to cover the checks drawn. Petitioner, Mr. Schreiber, and Mr. Wright are referred to as “players”, along with a group of about 25 farmers, who are described as “culpable”. Examination of AMCOR From July 1988 until October 1988, Vince Capobianco, a revenue agent assigned to the Laguna Niguel Examination Division, conducted a civil tax examination of the corporate tax returns of AMCOR for its taxable years ending November 30, 1985 and 1986 (the AMCOR corporate examination). Mr. Capobianco assisted Mr. Tadlock in the preparation of the fraud referral. Sometime after October 1988, he assisted in the examination of the income tax returns of certain AMCOR-sponsored partnerships. From March 1989 to November 1989, Mr. Capobianco assisted in a criminal investigation of AMCOR. Joint Civil-Criminal Investigation The fraud referral was received by respondent’s CID, and, on January 4, 1989, it was assigned to Douglas Watson, then aPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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