- 3 - the Internal Revenue Service (IRS) as a revenue agent in the Mansfield, Ohio, office. While in the Mansfield office, he became an industry specialist in the fields of healthcare, horse operations, and farming operations. In 1999, he was promoted to group manager and later promoted to large case manager. In 2004, petitioner was transferred to an IRS office in San Francisco, California, where he remained until he terminated his position in August 2005. During petitioner’s entire employment with the IRS, he either audited or supervised the audits of taxpayers. B. Dr. Michael Karason Dr. Michael Karason (Dr. Karason), petitioner’s younger brother, is a podiatrist licensed to practice in the States of Ohio, Pennsylvania, and California. At the time of trial, he practiced podiatry out of offices in Harrisburg and Elizabethtown, Pennsylvania. On December 21, 2000, Dr. Karason executed a “Bill Of Sale And Agreement” (purchase agreement) to purchase the Harrisburg podiatry practice of Dr. Harold A. Flom, D.P.M. (Dr. Flom) for $31,000. The closing date was January 13, 2001. Dr. Flom’s podiatry practice consisted of intangible assets, which included patient lists, patients’ telephone numbers, and patients’ files, and medical equipment, which included furniture, office items, workroom items, and items in two treatment rooms. Each treatment room’s items included a podiatry chair, a stool, a sitting chair,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007