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While waiting for the information on Lawrence's examination,
on September 16, 1991, Agent Red issued an IDR to the Abrahams
and provided a copy of it to Towner Leeper. Among other things,
the IDR specifically requested records and information with
respect to "loans made by taxpayers to all third parties
(including Miriam Lawrence) in 1987". With respect to many of
Abraham's bank accounts reviewed by Agent Red, the IDR requested
an explanation as to "why are a large amount of transfers being
made from and to this account from other accounts?" Once again,
Agent Red requested the daily logs of cash receipts and the cash
receipts journals for Abraham's law practice. The response date
for this IDR was September 27, 1991.
Also on September 16, 1991, Lawrence telephoned Agent Red
and asked that the response date for the August 27, 1991, IDR
issued to her be extended once again. This time she requested
that it be extended until October 15, 1991. In addition, she
indicated that she needed to have her records returned to her so
that she could respond. In response to her request, Agent Red
asked that she extend the period of limitations until March 15,
1992. She declined to do so. On September 24, 1991, Lawrence
retrieved what records she had provided to Agent Red.
On September 27, 1991, the response date for the September
16, 1991, IDR issued to the Abrahams, Agent Red telephoned Towner
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