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investigate further to determine whether the recording of the
house and vehicles in names other than petitioner was in fact
proper. Cox also was awaiting receipt of additional financial
information that petitioner had told him would be forthcoming.
Cox was not sure at this time that he would refer petitioner to
CID but thought that he should discuss with CID his belief that
petitioner’s case was a potential fraud case. Cox had a
suspicion at the time that petitioner was not being truthful with
him.
On November 7, 1994, petitioner met with Cox again and gave
him more financial information. Petitioner informed Cox at this
meeting that petitioner’s 1994 income to date was $22,180, rather
than $29,000 as previously reported. Petitioner also changed
certain line items that he had previously reported on the
financial statements. Petitioner and Cox had no further meetings
after this date.
On January 3, 1995, petitioner filed for bankruptcy under
chapter 7 of the U.S. Bankruptcy Code. On the same day, Cox
received a copy of that filing.
On or about February 8, 1995, Cox attempted to contact
petitioner’s daughter but was unable to do so. On February 8,
1995, Cox spoke to petitioner’s ex-wife as to the house in which
petitioner lived and the fact that it was listed in the name of
the daughter. Petitioner’s ex-wife informed Cox that she did not
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