- 14 - 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.),Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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