-13- obtain those consents but obtained them from Steele by contacting Leatherstocking’s authorized representatives. Kerzner did not threaten Steele or offer him any incentive to agree to the consents. Respondent resumed his audit of Leatherstocking in January 1994. At that time, respondent assigned the audit to Revenue Agent Robert Clements (Clements). Respondent also assigned to Clements the audits of the other entities related to Leatherstocking. Kerzner was not assigned those audits because he had worked on the grand jury case involving Steele. During his audit of Leatherstocking, Clements did not personally speak with or meet with Steele, who was then in prison, but primarily corresponded with Steele by mail. In obtaining the consents that Steele signed after January 1994, Kerzner did not threaten Steele or offer him any incentive to agree to the consents. Nor did Clements ever ask the limited partners of Leatherstocking to sign consents individually. Clements never had any contact with the Leatherstocking limited partners regarding the audit of Leatherstocking. On September 16, 1997, respondent issued the FPAAs for the subject years. Respondent never issued to Steele written notification that his partnership items would be treated as nonpartnership items. Respondent never issued to Steele written notification that he was under criminal investigation.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011