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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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