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1990, Towner Leeper met with Agent Red and provided certain
records relating to the prior examination of Abraham.
Due to other responsibilities and the delays he encountered
in attempting to obtain information with respect to Lawrence's
examination, Agent Red did not work on petitioners' examinations
from late October 1990, through January of 1991.
On February 13, 1991, Agent Red met with Towner Leeper and
Lawrence. Lawrence was present at this meeting in her capacity
as Abraham's office manager. Towner Leeper did not represent her
at this time with respect to her own examination. At this
meeting Agent Red was provided with some of the records that he
had requested in his July 23, 1990, IDR to the Abrahams. He
still had not received the information he requested in the IDR
issued to Lawrence on August 14, 1990.
On March 15, 1991, Agent Red issued a second IDR to the
Abrahams. He again asked for the daily log of cash receipts and
the cash receipts journal. He also asked for an "explanation of
the large [number] of transfers between accounts." In response
to the IDR of March 15, 1991, Agent Red met with Towner Leeper
and Lawrence on March 26, 1991. Agent Red was not provided with
the information he had requested in the IDR.
On May 28, 1991, in a letter to the respective
representatives of petitioners, Agent Red requested that the
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