Virginia Ferguson, f.k.a. Virginia Del Bosque, and Estate of Armand J. Del Bosque, Deceased, Lori Del Bosque, Special Administrator, et al. - Page 7

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               Ms. Pavlak believed that petitioners had misrepresented the            
          profitability of the limousine business on the Top Play income              
          tax returns that she had reviewed and relied upon in purchasing             
          Top Play.  On July 8, 1990, she met with petitioners and proposed           
          that they repurchase Top Play for $340,000.  Petitioners did not            
          respond to her proposal.  Thereafter, Ms. Pavlak sued petitioners           
          for fraud and misrepresentation with respect to her purchase of             
          Top Play.  She received a judgment in the amount of $95,000.                
               Because Ms. Pavlak believed that a portion of Top Play’s               
          cash receipts in 1989 had likely been derived from illegal                  
          activities, she contacted the U.S. Drug Enforcement                         
          Administration (DEA).  The DEA referred Ms. Pavlak to the                   
          Criminal Investigation Division of the Internal Revenue Service             
          (IRS).                                                                      
               In July of 1990, Tom Fisher, an IRS special agent assigned             
          to the Federal narcotics task force, began investigating                    
          petitioners’ business activities.  Agent Fisher determined that             
          petitioners had unreported income.  He believed that narcotics              
          and/or gambling activities were the possible sources for this               
          income.                                                                     
               Agent Fisher reconstructed petitioners’ incomes using the              
          net worth method.  Agent Fisher chose the net worth method to               
          compute petitioners’ incomes because (1) excessive cash had been            








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