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informed Mr. Black why they were there. As Agent O’Dell began
reading him his rights, Mr. Black interrupted him, said the
interview was over, and asked them to leave.
Agent McCarter, and later also Agent O’Dell, were forced,
because of Mr. Black’s refusal to provide requested bank and
other relevant records, to serve numerous IRS summonses on Mr.
Black, banks, and other third parties in order to obtain the
information necessary to determine petitioners’ income tax
liabilities for the taxable years 1991 and 1992.
During November 1994, Agent O’Dell provided Mr. Black’s
representatives with a printout of canceled checks and asked them
to have Mr. Black classify the purpose of the checks as either
business or personal. Over 3 months later, Mr. Black still had
not classified the checks. On March 4, 1995, Agent O’Dell wrote
Mr. Black’s representatives, again requesting that Mr. Black
classify the checks, and also asked that Mr. Black complete and
return the Cash On Hand Statement enclosed with that letter. On
March 15, 1995, Mr. Black’s principal attorney, Robert
Mendenhall, advised Agent O’Dell that Mr. Black “is being very
obstinate” and that he hoped that one of Mr. Black’s other
attorneys, who was meeting with Mr. Black “can convince him that
this is a serious matter”. On the basis of Mr. Black’s lack of
cooperation, the lack of adequate books and records of income and
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