Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner v. Commissioner

T.C. Memo. 2000-216

UNITED STATES TAX COURT CROP ASSOCIATES-1986, FREDERICK H. BEHRENS, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12532-90. Filed July 17, 2000. P has moved for dismissal or alternative relief based on respondent’s misconduct. Petitioner’s principal complaints are: 1. A civil investigation was carried out in the guise of a criminal investigation. 2. Conversations subject to the attorney-client privilege were unlawfully monitored. 3. Documents were unlawfully seized pursuant to a defective search warrant. Petitioner requests that…