- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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