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          mately one week thereafter, George D. Coupounas (Mr. Coupounas)             
          telephoned Mr. Kaply to advise him that on February 22, 1990,               
          petitioners had executed Forms 2848 authorizing Mr. Coupounas to            
          represent petitioners not only with respect to their taxable year           
          1987 that was being examined by Mr. Kaply, but also with respect            
          to their taxable years 1986 and 1988, and those forms were sent             
          to Mr. Kaply.                                                               
               On April 24, 1990, Mr. Kaply and Norman Murphy (Mr. Murphy),           
          who was Mr. Kaply's acting manager, met (April 1990 meeting) with           
          Mr. Coupounas about petitioners' returns for 1987 and 1988 that             
          were being examined.  At that meeting, Mr. Kaply asked Mr.                  
          Coupounas questions about the Indian Head business savings                  
          account and two of the accounts at Kennebunk, which were similar            
          to the questions that he had asked Mr. Dennett at the February              
          1990 meeting.  Mr. Coupounas informed Mr. Kaply and Mr. Murphy at           
          the April 1990 meeting that he would answer Mr. Kaply's questions           
          only if Mr. Murphy promised not to refer petitioners' case to               
          respondent's Criminal Investigation Division (CID).  When Mr.               
          Murphy declined to make any such promise, Mr. Coupounas indicated           
          that he was terminating the April 1990 meeting.                             
               Shortly after the April 1990 meeting, Mr. Kaply turned                 
          petitioners' audit over to CID, and that division began to                  
          investigate not only petitioners' taxable years 1987 and 1988,              
          but also their taxable year 1986.  Respondent's special agent,              
          Don Cote (Mr. Cote), was assigned to the criminal investigation             
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