Carlton H. Perry - Page 12

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          thereof, the names and phone numbers of sellers or real estate              
          brokers, or the asking prices of any such properties.                       
               Our reservations about the reliability of the real estate              
          log are compounded by the results of an examination of the com-             
          puter diskette on which the real estate log was saved that was              
          conducted by Leslie Sawyer (Ms. Sawyer), a computer investigative           
          specialist employed by the Internal Revenue Service.  The first             
          and last entries in the real estate log relating to the real                
          properties that petitioner purportedly visited during 1989 were             
          dated February 12, 1989, and December 7, 1989, respectively.  Ms.           
          Sawyer printed a directory listing of the computer diskette on              
          which the real estate log was saved, and that directory listing             
          indicated that that log was last saved at a time when the com-              
          puter system's date was set on December 7, 1989, which is consis-           
          tent with the date of the last entry in that log.  Ms. Sawyer               
          also used a computer program, known as "Norton Utilities", to               
          retrieve a document that was at one time saved on that computer             
          diskette and later deleted.  That document was substantially                
          identical to the real estate log and was last saved at a time               
          when the computer system's date was set on January 1, 1989.                 
          Petitioner did not offer an adequate explanation as to why a                
          document that was saved at a time when the computer system's date           
          was set on January 1, 1989, contained information with dates                
          after that date.                                                            






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