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to Abraham's law offices; information with respect to the sale of
certain property; information relating to certain investments;
and "[records] of all loans and repayments."
In Agent Red's letter to the Abrahams, he requested an
initial conference date of August 10, 1990; however, due to the
unavailability of the Abrahams' attorney, Towner Leeper, the
meeting was postponed until September 5, 1990. On September 4,
1990, Agent Red was advised in a telephone conference with Towner
Leeper that Abraham had been examined for prior years, similar
issues had been raised, and the matter had ultimately been
settled, mostly by concession on the Government's part. Towner
Leeper wanted Agent Red to review the materials of the prior
examination before Agent Red started the current examination.
They scheduled a meeting for the next day. Prior to the meeting,
Towner Leeper telephoned Agent Red and advised him that he was
having difficulty locating the file from the prior examination
and that he did not want to meet until he found the file. Agent
Red indicated that he was going to begin the examination by
visiting Abraham's law offices the next day. Agent Red was
advised by Towner Leeper that if he did so he would be
"physically removed from the premises." Apparently Agent Red
waited for the information from Towner Leeper. On October 23,
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