Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 15




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          purportedly engaged in farming in Mexico.  C.H.M. had entered               
          into 10 farming contracts (the 10 contracts) with AMCOR.  On                
          February 14, 1988, Mr. Goolkasian was contacted by Mr. Frame, who           
          identified himself as general counsel of AMCOR and asked about              
          his investigation of the 10 contracts.  Because of certain                  
          discrepancies in what Mr. Frame told him, Mr. Goolkasian became             
          suspicious of Mr. Frame.  Mr. Frame also represented Dodson and             
          McCoy.  On April 13, 1988, Mr. Goolkasian met with Mr. Frame in             
          pursuit of his investigation of Dodson and McCoy, and, on                   
          June 20, 1988, he met Messrs. Frame, Dodson, and McCoy in pursuit           
          of that investigation.  Mr. Goolkasian believed that, at one or             
          both of those meetings, Mr. Frame attempted to mislead him.  As a           
          result, Mr. Goolkasian grew suspicious.  Mr. Goolkasian came to             
          believe that there were one or more tax fraud conspiracies                  
          involving, variously, as conspirators, Dodson and McCoy,                    
          Mr. Frame, Barry Jones (an accountant for AMCOR), petitioner,               
          Mr. Wright, Mr. Schreiber, and AMCOR.  Mr. Goolkasian’s authority           
          to investigate AMCOR was limited because its principal place of             
          business was outside the district to which he was assigned, the             
          San Jose district.  By at least April 1988, Mr. Goolkasian had              
          communicated his suspicions about AMCOR to personnel in the                 
          Laguna Niguel Examination Division.  Mr. Goolkasian was                     
          instrumental in persuading personnel in the Laguna Niguel                   
          Examination Division to make the fraud referral.                            






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