- 12 - 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 specificPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011