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accounts for 1991, 1992, and 1993. This included deposit
information for both Mrs. Runkle’s Canyon Kennel account and
petitioners’ joint personal checking account.
Based upon this deposit information, Revenue Agent Andrews
concluded that petitioners had sufficient income to require each
of them to file tax returns for 1991, 1992, and 1993.
Neither petitioner produced any documentation to Revenue
Agent Andrews during the course of his examination of each
petitioner’s income tax liabilities for 1991, 1992, and 1993.
Criminal Investigation
Revenue Agent Andrews referred each petitioner’s case to
respondent’s Criminal Investigation Division. Criminal
Investigation Division Special Agent Matthew Fabina (Special
Agent Fabina) was assigned to investigate Mr. Runkle’s failure to
file income tax returns. Special Agent Fabina and Special Agent
David Diffenbach attempted to interview Mr. Runkle at his
personal residence on January 11, 1996. Mr. Runkle exercised his
Fifth Amendment rights and refused to speak with Special Agents
Fabina and Diffenbach.
After Mr. Runkle refused to be interviewed, Special Agent
Fabina contacted banks, insurance companies, and third-party
income sources to determine Mr. Runkle’s income, and Special
Agent Fabina issued summonses to these third parties. Special
Agent Fabina caused summonses to be served on banks for specific
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