Dennis E. Runkle and Debra A. Runkle - Page 27

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          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                 
               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 third                

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