Frank J. Gorgie and Rosalia Gorgie - Page 5




                                         - 5 -                                          
          examination by Agent Mazon.  The examination for the 1988 tax                 
          year concerned the same unreported income issue as the 1986 and               
          1987 years.                                                                   
               On December 8, 1989, Agent Mazon met Mr. Berg and told him               
          that the 1988 tax year had been opened for examination.  Agent                
          Mazon tendered IDR 5, which asked, among other things, for                    
          information supporting certain loan repayments.                               
               On December 19, 1989, Agent Mazon received a response to IDR             
          5.  The response dated December 13, 1989, also asked respondent               
          for a second time to issue a 30-day letter.                                   
               During the course of her investigation, Agent Mazon believed             
          that some of what petitioner told her was not true.  In                       
          particular, petitioner told Agent Mazon that he had an                        
          outstanding loan on which he made payments and that there was no              
          unreported income for the years in issue.  Agent Mazon discovered             
          the opposite to be true–-there was no loan and there was                      
          unreported income.  These inconsistencies led Agent Mazon to                  
          speak with her manager and fraud coordinator about the proper                 
          course of action.  She was given approval to forward the case to              
          respondent's Criminal Investigation Division (CID), which she did             
          on January 11, 1990.  On April 4, 1990, Agent Mazon received a                
          package from CID declining the fraud referral.                                
          On April 23, 1990, Agent Mazon mailed to Mr. Berg a Form                      
          4549, Income Tax Examination Changes.  On June 1, 1990, Agent                 






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011