But in March 1994, the IRS Criminal Investigation Division thought otherwise.

Less than 48 hours after she told IRS and Virginia Alcoholic Beverage Control agents her story, and on the basis of the bookkeeper's allegations alone, gun-wielding IRS agents and other law-enforcement officials raided Jewish Mother restaurants in Virginia Beach and Norfolk, as well as the homes of Colaprete and his general manager. They seized cash registers, computers, business records and every scrap of paper pertaining to the business.

Four months later, the IRS returned most of the goods. "We were never charged with any crimes," Colaprete testified. No one apologized. Colaprete was left to pick up the pieces of a damaged business and a shattered reputation.

"In the wake of all this, I find there is no system in place to defend me, or others like me," he told members of Congress. "I'd like to believe that someone takes responsibility for what has happened. ... If the example we set for our citizens is one of no accountability and no remorse, then our form of government -- the oldest surviving democracy on the planet -- cannot survive much longer."

The Jewish Mother raids showed an out-of-control government bureaucracy, legislators said. The Virginia restaurateurs' nightmarish experience -- reconstructed here from interviews, congressional testimony and court filings -- made national news and lent momentum to the most extensive overhaul of the IRS in nearly half a century. The reform bill contains a host of new taxpayer protections and provisions designed to improve the agency's accountability and end mismanagement and abuse. President Clinton signed the reform bill on July 22.

The new law makes seizure of business property a last resort, and a personal residence can't be seized without court approval. The IRS now has to follow a number of due-process requirements and other restrictions on tax collections.

The story isn't over, however. Some still question whether the reforms will protect taxpayers from the police-state brand of search and seizure Colaprete and his colleagues endured. And as for the Jewish Mother, it's still seeking justice. Colaprete and his colleagues have filed a civil suit against the IRS and other enforcement agencies in connection with the raids. That case is still pending.

Colaprete had always wanted to run his own show, so when he saw the opportunity to open a restaurant in Virginia Beach, he snatched it. Colaprete and his business partner, Theodore M. Bonk, a friend and fellow entrepreneur, opened the Jewish Mother in 1975. The New York-style eatery, as the name implied, was a place to go for "warmth, comfort and good food," says Colaprete, 55, whose Brooklyn accent has softened slightly after several decades in Hampton Roads.

Virginia Beach at the time was a resort city, not the growing, year-round community it is today. The pair weren't sure of their prospects. But the restaurant stuck to its deli roots with a menu of omelets, soups and hearty sandwiches, eschewing french fries in favor of homemade potato salad. During the summer, the kitchen didn't close until 3 a.m. A changing venue of live jazz, rock, blues, classical and even karaoke pulled in a young, late-night crowd. The weekend brunch attracted families. The Jewish Mother, one block from the ocean on Pacific Avenue, filled several niches. Its reputation and popularity steadily grew.

Growing businesses are always looking for new employees, and one of the people who showed up seeking work in late 1993 was Deborah Shofner. Her resume stood out, and manager Scotty Miller hired her. Based on her application and resume, he and Colaprete thought she had potential far beyond working the register at the Virginia Beach deli. They saw her helping with accounting, taxes and payroll, and she quickly became their bookkeeper.

Bolstered by their success in Virginia Beach, Colaprete and his partner decided to expand. They opened a second Jewish Mother in Norfolk on Christmas Day 1993. Like its counterpart in Virginia Beach, the restaurant employed about 75 people.

In December, Shofner went to Miller for a serious talk: She'd been in trouble with the law and was on probation, and she wanted him to hear the story from her first, in case her parole officer ever contacted him. She said if she got in trouble again, she could lose her child, which gave Colaprete confidence that the past was, indeed, in the past.

But in the months that ensued, there were some quirks in the Jewish Mother's accounts. Colaprete got a call from the restaurant's banks about overdrafts totaling almost $40,000. After further investigation, he and Miller found more discrepancies. An investment account Shofner purportedly set up at Merrill Lynch didn't exist. A meeting with her parole officer revealed that Shofner must have given herself a $1,000 Christmas bonus. When Colaprete and Miller confronted Shofner, she admitted to stealing and said she would make restitution.

Instead, she went to the IRS and the state Alcoholic Beverage Control board and claimed that Colaprete and Bonk had been "skimming" millions from the business, according to an IRS affidavit. She told agents her employers were making her keep two sets of books and stay mum about bags of cocaine that were stacked like cordwood on the premises. Shofner told authorities about her earlier criminal conviction for credit-card fraud in Florida. She said she expected to have her parole revoked for falsifying records for the Jewish Mother, but she claimed that she feared for her life and that of her toddler, according to court documents.

What happened next made the headlines.

On April 2, 1994 -- Saturday morning before Easter -- about 20 heavily armed law-enforcement agents in flak jackets burst into the Virginia Beach Jewish Mother and announced to manager Edy Miller that they were closing the place down. They yanked forks from customers' hands and told them they had to leave. While drug-sniffing dogs combed the premises, agents interrogated employees, tore apart booths and ransacked the upstairs office. They seized computers, business records, cash registers, Rolodexes, invoices, entertainment date books, even a car license plate.

Other raids were happening simultaneously.

At the Norfolk restaurant on Colley Avenue, Bonk was working the breakfast rush when about eight heavily armed agents stormed in, yelling to employees and patrons that no one was to leave or to touch anything. Bonk, who has heart problems, had to be helped to a chair. The agents carted away everything that was on paper, down to the employee schedules.

Scotty Miller had worked the late shift at the Virginia Beach restaurant and was at home in bed when he got a panicked call from his wife, Edy, a little after 9 a.m. The morning turned into a waking nightmare. "Scotty, something's wrong, come down here!" The phone went dead, and no one answered when he called back, so he jumped in the shower to wake up.

Ricky Miller, 12 at the time, was downstairs watching TV and eating a bowl of Cheerios. Scotty Miller heard his son scream, and he jerked open the shower curtain to find himself staring down the barrel of a 9mm pistol. Downstairs, his son was forced to the floor at gunpoint.

Miller's daughter Jennifer, 14 at the time, had three girlfriends over from a slumber party the night before. They were still in their pajamas. Two male agents, their weapons drawn, made the girls get dressed in front of them, despite requests for privacy.

About 15 agents combed the house, searching for contraband with K-9 units. Miller tried to call his lawyer and was physically restrained when he tried to use the phone.

Colaprete's home, a quarter-mile from the Virginia Beach restaurant, also was being ransacked. No one was home, though. Colaprete and his family had taken a trip to Jamaica to celebrate his son's first Holy Communion. They were in church as their front door was being torn from its hinges. Agents seized a personal safe, 12 years' worth of income-tax returns and other financial records. They impounded the family's two German shepherds.

That afternoon a neighbor found the dogs at the local pound, where the warden on duty said the animals were scheduled to be euthanized in the morning.

Easter Sunday is one of the most lucrative days of the year in the restaurant business. But on April 3, 1994, the Jewish Mother raids dominated the local news. In the face of it all, the two restaurants opened, but this time it was with borrowed cash registers and little else. The staff moved around in shock.

As a receipt from the raid on the Virginia Beach property, authorities gave Edy Miller a floppy disk that they said itemized what was seized. Colaprete and his partner later took the disk to a computer consultant to get a printout of its contents, but the disk was blank.

In the aftermath of the raids, Colaprete says he was a pariah. "No lawyer would call me at that time. No one was interested," he says. "They were probably very frightened that representing me could mean they would be investigated. It's the fear we all have."

The restaurants were devastated. The Jewish Mother's credit, which was good prior to the raids, plummeted overnight, Colaprete says. Wary vendors demanded cash upfront. Patrons were reluctant to return. Some parents of young employees decided it was an unsafe place to work. Colaprete's two children endured taunts about their "Mafioso" father. Business dried up at the newly opened Norfolk restaurant. The eatery closed in August 1994, eight months after an auspicious beginning.

Four nerve-wracking months after the Easter raids, Colaprete learned that the investigation was over. No charges were ever filed. A short time later, a yellow Ryder truck pulled up to the Jewish Mother in Virginia Beach, and three agents unloaded the boxes and equipment the government had confiscated in April, dumping them in a pile.

Some of the items seized are still missing, such as an heirloom watch Colaprete had received from his father. The watch was taken from the safe that was removed from his home.

"Following the raids, I could get no answers as to why all of this occurred," Colaprete said in his testimony. "I was met with 'No comment, Mr. Colaprete,' at every turn. Freedom of Information requests were ignored, ostensibly due to a backlog of such requests, and despite legally mandated time limits on such requests."

Colaprete says he endured a deep depression that immobilized him for a year. His former manager, Scotty Miller, also fared badly, wrecked both financially and emotionally, he told the Senate Finance Committee.

After a two-year court battle, Colaprete obtained the IRS affidavit that was the basis for the searches. For the first time, he got the full story of his bookkeeper's subterfuge. To his amazement, he discovered that agents had acted on Shofner's allegations alone -- with nothing to corroborate the ex-con's story.

"After seeing the affidavit, I realized how inept they were," Colaprete says.

Shofner is currently behind bars, serving a six year, 11-month sentence for embezzling from the Jewish Mother and forging company checks. She also has pleaded guilty to three counts of embezzlement in North Carolina, where she fled after the raids.

The IRS has declined to comment on the Jewish Mother case, citing federal privacy laws and the pending litigation.

Enforcement activity by the IRS is hard to gauge. Poor record-keeping and an antiquated computer system stymied the General Accounting Office's recent efforts to assess the extent of IRS abuses, GAO officials say.

The data that the IRS does have is too limited to provide much of a picture of anything -- such as the causes of improper actions or the types of taxpayers at the receiving end of IRS abuse.

Critics point to the antiquated operations as a source of most of the IRS' problems. Its computers date to the 1960s and have never been successfully modernized. "People keep trying to change the IRS culture," says John W. Lee III, a law professor at the College of William and Mary and a former tax attorney, but "we need to change the computer system." The IRS still can't pass an audit, even though it's in the auditing business, critics charge. "The oversight board won't be effective unless it gets good data," Lee adds. "And the IRS can't get good data because it doesn't have a computer system that works."

If you happen to be investigated by the IRS, there's a good chance the government won't prosecute. Of the IRS' 3,904 cases in 1996, half were tossed out because the Justice Department declined to prosecute, according to the clearinghouse data. About 40 percent ended in criminal convictions, and 8 percent ended in dismissals or not-guilty verdicts.

In that same year, the Office of the Taxpayer Advocate fielded 9,600 complaints involving allegations of inappropriate or premature collection, but the office doesn't routinely compile data on the resolution of those complaints, the GAO reports.

A lot of hype surrounds one particular point in the reform legislation -- the shift in burden of proof from the taxpayer to the IRS in court proceedings. This would only occur after the taxpayer had fully cooperated with the IRS during an audit, but the legislation does not fully define "cooperation."

Michael Mares, chairman of the American Institute of Certified Public Accountants' Tax Executive Committee, warned the Senate Finance Committee in January that the burden-of-proof provision could backfire. "Our concern was that this was going to make the IRS a lot more intrusive than they are today," he says, as the IRS could make overly broad demands for documents in an effort to make the taxpayer unwilling to comply.

Mares, a partner in the Newport News-based accounting firm of Witt, Mares & Co., also encouraged legislators to make the Taxpayer Advocate's Office independent of the IRS. "The fact that it is part of the IRS," he said, "may taint its objectiveness in the minds of taxpayers."

The reform legislation, however, does not address the raids Colaprete endured. In a press briefing following the congressional hearings, IRS Commissioner Charles O. Rossotti said: "Even if one of these allegations is true, that would be one too many, and we won't tolerate it." Rossotti, the former CEO of Fairfax-based American Management Systems, was recruited by the Clinton administration in 1997 to fix the agency's chronic computer glitches.

The IRS has since launched an independent review of its criminal investigation unit -- the division responsible for raids like those inflicted upon the Jewish Mother. A task force is scrutinizing IRS standards and methodology in conducting investigations and the impact its procedures have on the rights of those targeted. "The criminal investigation division of the IRS plays a pivotal role in fighting tax evasion, and it is critical that its operations be beyond reproach," Rossotti has said.

The Jewish Mother is finally on the upswing again. The stigma from the raids has dissipated, though Colaprete says the episode set the business back by years.

In 1996, he and Bonk formed a joint venture with several other individuals to expand the Jewish Mother beyond the beach. New Restaurants Inc. now operates two Jewish Mothers in Richmond and one in Portsmouth. A fourth restaurant, in Williamsburg, is a franchise.

Colaprete still wants his day in court: The Jewish Mother has filed a $20 million civil suit against the IRS and state and local law-enforcement agents, alleging violation of their constitutional rights to due process and against improper seizure. IRS attorneys have defended the raids, noting that search warrants are often based on information by informants who have checkered pasts. Shofner, the bookkeeper, had nothing to gain by lying to authorities. "It cannot be said that no reasonable law enforcement officer would have sought a search warrant under these circumstances," the IRS argued in a legal brief. "Even [the restaurant's owners] trusted Shofner, despite her record."

Colaprete says that the IRS has alleged that there was about $20,000 in unreported income from the restaurants and that marijuana was found in his home. But no drug charges have been filed, and the business has cleared state and federal tax audits without any money owed.

Since June of last year, the civil case has been held up in the U.S. Court of Appeals in Richmond. The parties are awaiting a ruling on a pretrial appeal by the state Department of Alcoholic Beverage Control, which claims that state agents cannot be sued in federal court.

In the meantime Colaprete says he gets calls every day from fellow taxpayers with their own horror stories of IRS abuse. "They call me just to have someone to listen to them. They can't get anyone to sympathize," he says. "I don't have answers, but I lend an ear."