-6- petitioners owed tax of $2,566 and $6,420.50, respectively. Petitioner did not submit with his 1990, 1991, 1992, or 1993 return the amount of tax reported as owed. In December 1992, the Commissioner assigned Michael Cox (Cox), a revenue officer in the Commissioner’s collection division, to collect assessed Federal income taxes shown in the Commissioner’s records to be owed by petitioner. Cox was not assigned to audit or examine any of the returns underlying those taxes, nor did he do so. On May 6, 1993, Cox concluded that the taxes were uncollectible, and he closed the case as such. Cox’s conclusion was based primarily on his receipt from petitioner of information on his finances and Cox’s finding at the local courthouse of no assets recorded in petitioner’s name. In 1994, John Voorhees (Voorhees), a special agent in the Commissioner’s Criminal Investigation Division (CID), was told by a law enforcement agency that it had been informed that Hickey was selling prescription drugs illegally. Later, in May 1994, Voorhees spoke to one of the agency’s confidential informants and was told that petitioners kept a large quantity of narcotics at their home and lived a lavish lifestyle. The informant told Voorhees that petitioners had paid for a lavish wedding and honeymoon in Ireland and that petitioners had primarily used cash to pay for home improvements (e.g., a Jacuzzi and expensive windows) and entertainment expenses (e.g., stereo equipment andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011