TEILBORG OPINION AND IRS COVERUP
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IRS Master File was requested multiple times by Quiel at trial. This would have contained the FBAR’s for 2000-03 or lack thereof.
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After the numerous attempts to obtain Quiel’s IRS IMF, Quiel learned from an IRS agent that the criminal investigations unit in Phoenix was holding his file.
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Judge Teilborg denied Quiel access to his IMF file from the IRS. Teilborg ruled on August 16, 2013, “Quiel claims that the Court should have refused to admit redacted documents that the defense was unable to review….. the Court notes that Quiel objected to the admission of IRS Form 4340 and sought that the entire IMF file be disclosed at trial. This objection was overruled…”
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Judge Teilborg ruled on September 28, 2018 , “the court will not reconsider its prior finding that Petitioner procedurally defaulted this claim, because “it involves information that (Petitioner) could have learned with reasonable diligence prior to appeal.”
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Judge Teilborg acknowledges in his first order in 2013 that Quiel sought the entire IMF file be disclosed at trial but contradicts himself in the next order in 2018, stating it could have been learned prior to appeal.