- 7 - After petitioner husband’s plea agreement, Gim Baker (Baker), a revenue agent for the Internal Revenue Service (IRS), was assigned to examine petitioner husband’s 1989 Federal income tax liability and petitioners’ 1990 joint Federal income tax return. Baker issued letters to both petitioners, requesting them to provide documentation such as income records and expense records. In response, petitioner husband sent Baker a letter stating that it was impossible for him to collect the necessary documents while he was incarcerated and requesting that the civil examination be postponed until his projected release in 2000. Petitioner wife–-whose liability related only to taxable year 1990--refused to provide the requested information until the IRS showed her what information it had in its possession. In conducting the civil investigation, Baker relied on the criminal net worth computation rather than performing an independent income reconstruction for either year in issue. Except for her unsuccessful attempt to procure information from petitioners, Baker conducted no investigation regarding petitioners’ finances and did not verify the numbers contained in the criminal net worth summary. Instead, she copied the criminal net worth summary that was attached to petitioner husband’s plea agreement, using identical numbers to calculate the increases in net worth for each of the taxable years 1989 and 1990 but making certain modifications. For instance, in drafting the notice ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011