Dennis E. Runkle and Debra A. Runkle - Page 12

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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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Last modified: May 25, 2011