Frank H. and Marla C. Black - Page 4
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Petitioners filed timely joint Federal income tax returns
for taxable years 1991 and 1992. Mr. Black prepared a draft of
the 1991 joint return and took it to a certified public
accountant (C.P.A.) for review. The C.P.A. made some minor
corrections, then used the data shown on the draft to create a
computer-generated 1991 joint return. The 1992 joint return was
prepared by an accountant based upon computer printouts of income
and expenses and oral information provided by Mr. Black.
Internal Revenue Service (IRS) Revenue Agent Margaret
McCarter (Agent McCarter) was assigned to the examination of
petitioners’ joint returns for the taxable years 1991 and 1992.
Agent McCarter’s initial contact with Mr. Black occurred on
May 11, 1993, when she mailed him a letter advising him that
his 1991 income tax return was being examined and scheduling an
appointment for May 24, 1993.
Mr. Black refused to meet with Agent McCarter. As a result,
most of Agent McCarter’s later contacts were with the
representatives to whom Mr. Black delegated powers of attorney.
On May 26, 1994, Agent McCarter referred Mr. Black’s case to
the IRS Criminal Investigation Division.
On October 18, 1994, IRS Special Agent Dennis O’Dell (Agent
O’Dell) and Agent McCarter went to meet with Mr. Black at his
place of business in Charlotte, North Carolina. After arriving,
they introduced themselves to Mr. Black, and Agent O’Dell
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Last modified: March 27, 2008