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Leeper. Towner Leeper advised Agent Red that the information was
being gathered and would be provided by October 31, 1991.
Given the lack of cooperation that Agent Red was
experiencing in the examinations of petitioners, after consulting
with his group manager, he decided to issue summonses to Lawrence
and to the Abrahams. Agent Red had previously issued summonses
in about 5 percent of his cases. The summonses were issued on
October 1, 1991. In each case, the summons requested information
relating to loans and repayments.
The summons issued to Lawrence was returnable on October 15,
1991. On that date she appeared at the summons conference with
Towner Leeper, who now represented her. At the conference
Lawrence either refused, or failed to provide, any explanation
with respect to the checks she had written on, or deposited in,
her accounts. With respect to any loans between her and Abraham,
she indicated that the only documentation for the loans consisted
of the canceled checks between the two. She did not know the
outstanding balance of her indebtedness to Abraham, and with
respect to any interest that he charged her, she indicated that
she was charged "the going rate at the time of the loans."
The conference with respect to the summons issued to the
Abrahams took place on October 16, 1991. Abraham appeared
together with his representative, Towner Leeper. The conference
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