-11- realize that the house was in the daughter’s name and that the daughter was a law student who worked part time. Petitioner’s ex-wife informed Cox that the daughter and son (of petitioner and his ex-wife) lived with the ex-wife and that she did not believe that the daughter could afford to pay any expenses related to the house. Following this conversation, Cox believed that he should discontinue his case as to petitioner and refer him to CID for criminal prosecution. Shortly before April 21, 1995, Cox met with Voorhees for the first time after reopening the collection case and discussed with him whether the facts of petitioner’s case, as Cox believed them to be, supported his making of a criminal referral of petitioner to CID. On April 21, 1995, Cox prepared the requisite paperwork to refer petitioner’s case to CID, and Cox forwarded the case to CID. The essence of Cox’s referral was that petitioner was evading the payment of his assessed Federal income tax liability in that (1) he claimed that he did not own the house in which he lived; (2) the house was in the name of his teenage daughter, who did not work full time; (3) his ex-wife, the daughter’s apparent custodial parent, had no knowledge of any such ownership by the daughter; and (4) the house, if in fact owned by petitioner, could be used to pay his Federal income tax liability. On or about June 23, 1995, Voorhees began the criminal investigation of petitioner pursuant to Cox’s referral and recorded for the firstPage: 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