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Because Mr. Black refused to provide relevant records, Agents
McCarter and O’Dell were forced to serve IRS summonses upon Mr.
Black, banks, and other third parties.
Mr. Black’s failure to cooperate caused frustration to his
own representatives. 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. More than 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 that “afternoon, can convince him that this is a serious
matter”.
Petitioners also have a history of claiming inappropriate
charitable deductions first to ULC and to NFBC. On their joint
returns for taxable years 1979, 1980, and 1981, petitioners
claimed deductions for charitable contributions to the Universal
Life Church of $59,182, $57,181, and $33,629, respectively.
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Last modified: March 27, 2008