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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
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