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copies thereof, must be purged from the Criminal
Investigation Division files prior to closing in turn
to the Chief, Examination Division.
Administrative Proceedings Against Petitioner
At some point during 1997, Marco I. Minervini of
respondent's Appeals Office in New York transmitted by facsimile
a file copy of a so-called 30-day letter to Sylvia McGee of the
Manhattan Examination Division. The 30-day letter was dated May
21, 1996, and was addressed to petitioners. It proposed
adjustments to their taxes for the year 1986. The letter advised
that petitioners would have 30 days to have respondent's proposed
adjustments reviewed in respondent's Appeals Office. It
contained two proposed upward adjustments for petitioners' income
in 1986–-one for $834,857 in short-term capital gains and the
other for $4,249,563 in long-term capital gains. An accompanying
explanation stated that the adjustments in question were "as set
forth in Government exhibit #3, 90-CR-777-1." Additionally, the
30-day letter included the following identical explanations
regarding each of the two proposed adjustments: "These exclude
transactions in the names of Ingrid Doorn and Marc Ford, either
reported by taxpayers or reported elsewhere (by Marc Ford)."
Marc Ford is petitioner's son.
Thereafter, respondent's District Counsel in Manhattan
(District Counsel) sent a memorandum dated October 13, 1998, to
the Chief of Manhattan Appeals, with an attention line to M.
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