Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 13




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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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