Patrick Carlin Hickey, et al. - Page 9

                                         -9-                                          
          learned that petitioner’s daughter was listed as the owner of the           
          referenced house, which then was assessed at $108,500.  Cox did             
          not find at either place the recording of any asset in                      
          petitioner’s name.                                                          
               As of November 4, 1994, the Commissioner’s records showed              
          that petitioner owed more than $28,000 in back taxes, interest,             
          and penalties.  On that day, petitioner gave Cox some additional            
          financial information, including lien information for the Jeep              
          Wrangler, and Cox informed petitioner that his financial status             
          as reported to Cox allowed petitioner to pay at least $400 per              
          month towards his Federal income tax liability.  Petitioner                 
          replied that he must not have given Cox all of his actual                   
          financial information, as petitioner indicated he was unable to             
          make that minimum payment, and requested additional time to                 
          disprove the calculated minimum payment.  Later on that day, Cox            
          recorded in his “Investigative History Sheet” (history sheet) his           
          plan of action for the case.  His plan stated:                              
               discuss case with CID for possible fraud, I believe TP                 
               has submitted a fraudulent financial statement with                    
               regards to vehicles, Income and possibly Real Property.                
               I also believe that his 30-9312 could also be                          
               fraudulent with regards to his dependents and income.                  
               TP has $35,000 in vehicles which are free and clear and                
               I don’t see where his financial statements or Income                   
               tax returns support this.                                              
          As of this time, Cox did not believe that he had the requisite              
          firm indication of fraud that would support referring                       
          petitioner’s case to CID.  Instead, Cox thought, he should                  





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