Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 18




                                       - 18 -                                         
               The investigation of Dodson and McCoy was closed sometime              
          prior to March 1992, after Dodson and McCoy had pled guilty to              
          filing false income tax returns.                                            
               Grand Jury Investigation                                               
               In March 1990, the District Director, Laguna Niguel,                   
          California, requested William Shipley, Regional Counsel, Western            
          Region, to recommend to the Department of Justice (the                      
          Department) that the Department institute a grand jury                      
          investigation into the activities of petitioner, Messrs.                    
          Schreiber and Wright, and two others (but not AMCOR) in                     
          connection with the operation of a fraudulent tax shelter.                  
          Mr. Shipley made that recommendation, and the Department accepted           
          it; a grand jury investigation was commenced in June 1990 (the              
          grand jury investigation).                                                  
               The joint investigation ended when the grand jury referral             
          was accepted.  During the course of the grand jury investigation,           
          the Laguna Niguel Examination Division continued the AMCOR                  
          partnerships examination.                                                   
               On March 1, 1993, the Department notified Mr. Shipley that             
          the Department was declining prosecution of the subjects of the             
          grand jury investigation.  The letter so notifying Mr. Shipley              
          stated:  “Although evidence uncovered to date indicates that the            
          principals of * * * [AMCOR] were involved in the operation of a             
          fraudulent tax shelter, this office has concluded that two                  






Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  Next

Last modified: May 25, 2011