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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 a
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