Frank H. and Marla C. Black - Page 5

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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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