- 21 - relies on the list of actions in the petitioning partners’ memorandum.3 The list in petitioner’s memorandum is as follows: 1. Use of fraud, deceit and trickery in order to procure evidence for a criminal investigation. 2. Misuse of a civil tax examination as a guise to secure evidence for use in a criminal tax investigation. 3 The list in the petitioning partners’ memorandum is as follows: 1. Misuse of a civil tax examination as a guise to secure evidence for use in a criminal tax investigation. 2. Invasion of privileged attorney-client communications through unlawful monitoring of meetings and telephone conversations. 3. Deprivation of access to vital business books and records by their seizure and extended retention pursuant to a search warrant that was improperly sought and wrongfully issued on the basis of material misrepresentations of fact made under oath. 4. Gross negligence in the care and maintenance of the seized records while in the Government’s custody so that key documents were lost and important computerized information rendered useless. 5. Misrepresentation of the status and duration of a related grand jury investigation in a manner that seriously impeded the civil tax litigation. 6. Intimidation of targets of the criminal tax investigation with the result that their assistance and testimony was unavailable to Petitioners. 7. Coercion and improper inducement by Government agents of witnesses to procure favorable -- and bury unfavorable -- testimony.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011