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petitioner's 1991 return. Mr. Todar kept those records at the
clinic. Sometime in July 1992, certain of those records were
destroyed or otherwise rendered illegible (destroyed records)
when the clinic was vandalized (clinic break-in). Mr. Todar
immediately notified petitioner of the clinic break-in and
advised him to attempt to duplicate the destroyed records. Most
of those records consisted of copies of checks, the originals of
which petitioner had retained and could copy again for Mr. Todar.
The balance of the destroyed records consisted principally of
receipts from various contractors (contractor receipts) that had
built a commercial kitchen at petitioner's residence for his
wife, who was engaged during 1991 and 1992 in certain catering
activities. Mr. Todar advised petitioner after the clinic break-
in to contact those contractors in order to obtain copies of the
contractor receipts that had been destroyed or letters from those
contractors concerning their construction work for petitioner's
wife. However, petitioner obtained few, if any, of such copies
or letters.
Petitioner knew at the time that Mr. Todar notified him of
the clinic break-in that he had until August 15, 1992, within
which to file his 1991 return. Thereafter, petitioner, with the
assistance of Mr. Todar, requested and received a second exten-
sion of time until October 15, 1992, within which to file that
return.
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