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revenue agent with CFC’s books or records, refused to comply with
a subsequent summons for the same books and records, and only
complied with a second-chance letter to provide those documents
approximately 4 months after the initial summons. The revenue
agent issued two additional document requests after reviewing the
initial documents, but Mr. Cordes specifically refused to provide
any additional information. The revenue agent then issued a
summons for those documents, as well as a summons for the books
and records containing information regarding Mr. Cordes’s 1995
taxable year; those summonses were issued to Eddy Ben Cordes,
president of CFC, as well as to Bill Burns, Viola Burns, and
Michael Heinz (other administrative personnel). The revenue
agent also issued a summons to Mr. Cordes to produce his personal
ledger cards. Mr. Cordes denied he had those cards and refused
to comply with the summons, although Mr. Burns and Mrs. Burns had
informed the revenue agent that Mr. Cordes did keep those cards.
Eventually, Mr. Cordes produced 108 ledger cards in partial
compliance with a judge’s order. The revenue agent was later
able to obtain more ledger cards from Mr. Cordes but cumulatively
obtained cards pertaining to fewer than 200 of the 1,168 notes
Mr. Cordes had purchased from CFC. Mr. Cordes’s repeated
refusals to cooperate with the revenue agent and his concealment
of documents strongly indicate that Mr. Cordes’s behavior was
fraudulent.
(3) Mr. Cordes provided false documents to the revenue
agent. Mr. Cordes, in an effort to prove there were no personal
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