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special agent working in Laguna Niguel, California. Mr. Watson
accepted the fraud referral, but not with respect to AMCOR, since
he felt it more appropriate to investigate individuals rather
than a corporation for fraud. Mr. Watson accepted the fraud
referral as to Mr. Schreiber, an individual, and made him the
target of his investigation. Subsequently, the Laguna Niguel
Examination Division and Mr. Watson commenced a joint civil and
criminal investigation into AMCOR, its principals, and the AMCOR-
sponsored partnerships’ tax shelter activities. The Internal
Revenue Manual does not prohibit such joint investigations. On
August 22, 1989, petitioner and Mr. Wright also became subjects
of Mr. Watson’s investigation.
Investigation of Dodson and McCoy
In 1987, Wilbur J. Goolkasian was a special agent in
respondent’s CID, assigned to the San Jose, California, district
(the San Jose district), with post of duty in Fresno, California.
In 1987, Mr. Goolkasian received information from the San
Francisco office of the Securities and Exchange Commission
concerning “a large tax shelter fraud scheme” targeted at
investors in the Fresno, California, area. That information led
him to investigate two individuals, Ronald Dodson and Ray McCoy
(Dodson and McCoy). During his investigation of Dodson and
McCoy, Mr. Goolkasian learned that Dodson and McCoy were
principals of a Mexican corporation, C.H.M. de Mexico (C.H.M.),
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