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whether respondent has attempted to conduct a criminal
investigation under the guise of a civil examination. See United
States v. Peters, 153 F.3d at 452 (and cases cited therein). A
firm indication of fraud is different from an initial indication
that fraud exists, and it is more than a mere suspicion of fraud.
See, e.g., United States v. Peters, supra at 455-456. The
determination of a firm indication of fraud is a factual
determination that can only be determined on a case-by-case
basis. See id. at 456. Moreover, only the victim of conduct
improper under the Fourth Amendment has standing to challenge
such conduct by seeking suppression of the evidence obtained
under the exclusionary rule. See United States v. Payner, 447
U.S. 727, 731 (1980). Nor does a Federal court’s inherent
supervisory power authorize the court to suppress otherwise
admissible evidence on the ground that it was seized unlawfully
from a third party not before the court. Id. at 735.
C. Discussion
Petitioner has failed to prove the particulars of
respondent’s examination with respect to the 1986 partnership
return. See supra sec. VII. During his investigation of Dodson
and McCoy, Special Agent Goolkasian came to believe that there
were one or more tax fraud conspiracies involving, variously, as
conspirators, Dodson and McCoy, Mr. Frame, Mr. Jones, petitioner,
Mr. Wright, Mr. Schreiber, and AMCOR. On October 26, 1988, the
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