Question: The question ask you to read a fact pattern and answer a question or respond to a prompt. For your ease of reference, the fact

The question ask you to read a fact pattern and answer a question or respond to a prompt. For your ease of reference, the fact pattern is repeated in the beginning of each question on Canvas. Please limit your response to 1000 words per question.

Fact Pattern

Willy Wonka is under investigation by the IRS Criminal Investigations Division. He is the president of Golden Ticket Enterprises, an S-corporation. Beginning in 2017, Willy Wonka, created a Florida corporation, Oompa Loompa Marketing, Inc. Oompa Loompa sends Golden Ticket a monthly invoice for $10,000. Every month, Golden Ticket writes a check to pay the invoice from Oompa Loompa. Willy has his secretary deposit this check to Oompa Loompa in a bank account at Never Never Land Bank, located outside of the United States.

Golden Ticket files an 1120-S every year and deducts the payments to Oompa Loompa as a business expense.

Willy timely filed personal tax returns for 2018, 2019, and 2021 (he was on extension for 2019) but he failed to file a personal tax return for 2020. On March 1, 2022, an IRS agent showed up at the Chocolate Factory and asked Willy if he had control over a bank account outside of the United States, and Willy said no.

Willy was last seen at Never Never Land Bank withdrawing $50,000 cash from the bank account held in the name of Oompa Loompa.

Question 1:

You are the IRS Special Agent who has been tasked with leading the grand jury investigation into Willy Wonka's tax affairs. What information would you seek through the grand jury? What documents would you seek? What witnesses would you want to interview? Explain your reasoning.

  • Please provide 1000 words for the answer
  • Do not provide answer that already posted

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