Frank H. and Marla C. Black - Page 27

                                       - 27 -                                         
          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              
               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.                 

Page:  Previous  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  Next 

Last modified: March 27, 2008