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limitations periods relating to the examinations be extended for
a period of 1 year until October of 1992. Petitioners agreed to
extend the periods only until December 31, 1991, an extension of
2 months.
On June 3, 1991, Agent Red issued another IDR to Lawrence
requesting the same information that had been requested in the
August 14, 1990, IDR, as well as additional information on other
subsequently discovered bank accounts.
Because the IDR's issued to Lawrence were not fully complied
with, Agent Red issued summonses to various banks in July of 1991
seeking certain of the information that Lawrence failed to
provide. After receiving some records directly from Lawrence and
some of the missing bank statements from the banks, Agent Red
prepared check and deposit spreadsheets for each of Lawrence's
bank accounts. On August 27, 1991, he issued yet another IDR to
Lawrence and attached copies of the spreadsheets he had prepared
from the bank records. He requested that Lawrence identify the
source of each deposit listed on the spreadsheets and explain the
purpose of the checks written on the accounts. The response date
for the IDR was September 12, 1991. On September 11, 1991,
Lawrence telephoned Agent Red and requested a 1-week extension,
to which he agreed.
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