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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 first
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