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Dr. Dean's Request for Conference
8 July 2003
Benjamin W. Beard
Assistant U.S. Attorney
21 East Garden Street
Suite 400
Pensacola, Florida 32501
Dear Mr. Beard,
Pursuant to CFR Title 26, Section 601.107, DOJ Tax Division Directive No. 86-58, para (5), and Section 6-4.214 "Conferences," U.S. DOJ Tax Division Criminal Tax Manual (1994), I again request a district Criminal Investigation Conference or meeting with you, to determine "the alleged fraudulent features of the case" and "the basis, nature, and other essential elements of the proposed criminal charges" that justify your initiating a criminal/Grand Jury investigation against me.
At this conference/meeting, I shall expect you to answer the following questions with regard to Title 26 USC Sections 7201, 7203, and 7212, and any other statute you may allege may apply to me. Answers to these questions and exhibits presented by me in regards to your investigation shall be made part of the record and shall also be made part of my personal file, maintained by the Internal Revenue Service, or any other division, section, or any unit of the Department of the Treasury.
1. State, with particularity, the specific type of "income tax," i.e., direct or indirect, I allegedly evaded and defeated that was allegedly due and owing to the United States.
2. State the specific law, i.e., Statutes at Large, which imposed said "income tax" on me in violation of 26 USC 7201.
3. Describe and/or identify, with particularity, the specific "income tax return," "required by law," which I allegedly failed to make in violation of Title 26, USC, Section 7201.
4. State the specific law (Statutes at Large) or regulation, (Code of Federal Regulations) requiring me to "make an income tax return."
5. State, with particularity, the specific type of "substantial income tax," i.e., direct or indirect, I allegedly "owed to the United States of America."
6. State, with particularity, the specific type of "income tax," i.e., direct or indirect, that I failed to "pay the Internal Revenue Service."
7. Describe, with particularity, the essential elements involved for me to support a 26 USC 7201 conviction.
8. Describe, with particularity, the nature of 26 USC 7201 and how it applies to me.
9. State, with particularity, the specific "proper officer of the internal Revenue Service," as verified by the lawful Treasury Delegation Orders, Commissioner's Delegation Orders, or Regional Office Delegation Orders, wherein I was required to have made said "income tax return" or paid said "income tax."
10. State, with particularity, the specific type of "gross income" I allegedly "received."
11. Describe, with particularity, the locations and times where I willfully attempted to evade and defeat the said income tax due and owing by me to the United States of America to any proper officer of the Internal Revenue Service… and failed to pay the Internal Revenue Service said income tax, pursuant to 26 USC 7201.
12. Identify who "any proper officer of the Internal Revenue Service" is/are that I was "required by law" "to make an income tax return to" during the years in question.
13. Identify who "all proper officers of the United States of America" are, that I was to have allegedly concealed "my income and assets from."
14. Identify, with particularity, any "income and assets" that were allegedly concealed by me.
15. Describe with particularity, where and from whom I received said "gross income" during the years in question.
16. Identify, with particularity, who the person or other proper officer of the Internal Revenue Service are, who can properly certify and /or authenticate that "returns" were or were not made, pertaining to me for the years in question.
17. State on what specific dates did the above persons discover "returns" were or were not made to the IRS by me for the years in question.
18. State with particularity, who the above persons told that "returns" were or were not made to the IRS by me for the years in question.
19. State, with particularity, the method that was used in determining that "returns" were allegedly made, or not made by me for the years in question.
20. State, with particularity, from what specific location did the above persons obtain the information that I allegedly did, or did not make a "return."
21. State, with particularity, where the enforcement regulations or regulations thereunder for 26 USC 7201 are to be found in Title 26 USC, or Title 27 USC or regulations thereunder.
22. State, with particularity, the legal description of the "United States of America" and its legal location.
23. Para 6-4.270 of the U.S. DOJ Tax Division Criminal Tax Manual (1994), "Criminal Division Responsibility," states that "The Criminal Division has limited responsibility for the prosecution of offenses investigated by the IRS. These offenses are: excise violations involving liquor tax, narcotics, stamp tax, firearms, wagering, and coin-operated gambling and amusement machines; malfeasance offenses committed by IRS personnel; forcible rescue of seized property; corrupt or forcible interference with an officer or employee acting under the internal revenue laws; and unauthorized mutilation, removal or misuse of stamps. See 28 CFR Section 0.70." Therefore, please state, with specificity and particularity which of the above offenses apply to me, and under which of these authorizations the Criminal Division is investigating me for a potential prosecution.
Yours truly,
Ward Dean, M.D.
cc: Tanya Burgess
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