- 4 - 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’DellPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008