- 27 - Runkle declared that she considered the conference concluded. Further, petitioners insisted on taping the interview, and Mr. Runkle insisted on the revenue agent’s telling Mr. Runkle what Code section required him to file tax returns. Revenue Agent Andrews testified that he found this questioning, in the presence of four witnesses who refused to identify themselves, to be intimidating. Neither petitioner produced any documents or records to Revenue Agent Andrews during the course of his examination for 1991, 1992, and 1993. After concluding that petitioners would not comply with his requests, Revenue Agent Andrews had to resort to contacting third parties to verify income information and, after referring each petitioner’s case to respondent’s Criminal Investigation Division, petitioners continued their tactics of failing to attend meetings that necessitated Special Agent Fabian to issue third-party summonses. Petitioners on no less than four separate occasions filed petitions to quash respondent’s summonses and prevent respondent’s access to this information. A taxpayer’s efforts to quash the Commissioner’s summonses may be indicia of fraudulent intent when the taxpayer otherwise refuses to cooperate with the Commissioner. Wedvik v. Commissioner, 87 T.C. 1458, 1470 (1986). Mr. Runkle also sought to dissuade third parties from complying with the summonses by threatening to sue the thirdPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011