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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,
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