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meeting set for July 27, 1994. However, petitioners and Clement
never met that day or at any other time prior to October 31,
1995, although they did have a telephone conversation on August
1, 1994. Clement and petitioner discussed the receipt of the
$840,000 from Sanrio. Petitioner did not provide a direct answer
to Clement's inquiry about this sum. This conversation was
Clement's last personal contact with either petitioner before
respondent issued the notice of deficiency.
On August 2, 1994 petitioner left a voice message for
Clement, informing him that petitioners had received an
appointment letter, a Form 872, and an information document
request (IDR) seeking books and records needed to audit the
return. Petitioner once again stated that the Paus would not
extend the period and that they would be unable to obtain the
documents requested because of the short time left in the period.
Clement then served a summons on petitioners on August 5, 1994,
for the records identified in the IDR. Prior to the issuance of
the notice of deficiency, the Paus did not produce any books and
records requested from them by the IDR.
In addition to the summons served on petitioners, Clement
issued summonses to financial institutions and a title company.
He received the books and records from these entities after the
notice of deficiency had been mailed to petitioners.
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