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was taking place. Prior to July 1993, in response to a document
request dated February 8, 1993, Guerra sent Revenue Agent Allen
Sohrt (Agent Sohrt) a copy of the Note, which was unsigned. On
July 16, 1993, Guerra met with Agent Sohrt, at which time Agent
Sohrt requested a signed copy of the Note as well as copies of
any checks showing payments on the Note. Guerra looked for the
documents requested at the July 16 meeting and did not find any
copies of checks, so he notified Eagleson. On July 22, 1993,
petitioner made his first payment on the Note, equal to two
principal payments of $15,400 each and interest accrued to date
of $36,961.68. On August 2, 1993, Guerra sent Agent Sohrt a
signed copy of the Note and stated in a cover letter that
petitioner had missed the first payment due on the Note (the July
2, 1992, payment), in part because of the failure of the
accountants at Davidson, Eagleson to notify him the payment was
due. At the time he sent this letter, Guerra had not been made
aware that the Note had been signed in 1992, and the letter made
no mention of when the Note had been signed. On October 8, 1993,
Agent Sohrt wrote Guerra asking petitioner to provide a signed
statement as to when the Note had been signed. Later that month
Guerra drafted a letter for Eagleson's signature stating that the
Note had been signed on or shortly after May 26, 1992, even
though it was effective July 2, 1990. This letter advised that
the accountants were partly responsible for the failure to
prepare the Note at the time of the transfer of the Ranch.
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