DiVivo v. Egger

FRANK A. KAUFMAN, Chief Judge.

In March 1977, the Internal Revenue Service (IRS) began an income tax investigation of plaintiffs Victor F. DiVivo and his wife. The IRS completed the criminal tax investigation in June 1979. The special agents in charge of that investigation recommended that DiVivo be prosecuted for evasion of his individual income taxes for the years 1974, 1975 and 1976. The case then was referred to the office of the United States Attorney in this District for prosecution. In January 1981, a grand jury investigation of DiVivo’s tax affairs was commenced by that office. Three…