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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.
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