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case, what the Appeals officer considered to be critical
information was not provided to Agent Red. Haddad's reports were
not prepared until after the close of Agent Red's examinations.
Petitioners contend that a similar issue, involving items of
omitted income, was raised and conceded by the Government in a
prior examination of Abraham's income tax return for an earlier
year. Petitioners argue that it was unreasonable for respondent
to once again pursue the issue. There is nothing in the record,
however, that indicates the level of Abraham's cooperation during
a prior examination or what explanations were provided. In any
event, our view of the significance of a prior examination
differs from petitioners'. We note that in his July 23, 1991,
initial appointment letter to the Abrahams, Agent Red
acknowledged that it might be unproductive to examine matters
that had been previously considered and resolved. We do not view
unexplained bank deposits to fit within the category of
previously examined matters referred to in that letter.
Petitioners' attack on the reasonableness of respondent's
position is severely undermined by their failure to cooperate
with Agent Red during the examinations. Cf. Inman v.
Commissioner, T.C. Memo. 1996-16. Agent Red requested, and was
entitled to receive, explanations for the transactions reflected
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