Patrick Carlin Hickey, et al. - Page 6

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          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 and             






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