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specifying for examination particular items shown on petitioners’
1991 or 1992 tax returns.
After The Meeting
On April 25, 1996, Ward prepared the Form 872 and telephoned
petitioners’ representative. She left a message at his office.
She also left messages on April 30, May 3, May 6, May 10, and May
13. Petitioners’ representative did not return these calls.
On June 20, 1996, petitioners’ representative spoke with the
chief of the 90-Day Review Section. This section chief then
directed Ward to return to petitioners’ representative’s office
regarding the Form 872.
On June 26, 1996, Ward went to petitioners’ representative’s
office with the Form 872. Petitioner’s representative refused to
sign the Form 872, saying that he was willing to consent to a
period of limitations extension if Ward limited the scope of her
examination. Ward refused to agree to a limited-scope extension,
without discussing this with her manager. The parties did not
extend the limitations period for 1991 or 1992, apart from the
1991 extension that had previously been agreed to in order to get
the IRS to move the audit from El Paso to Dallas. Petitioners’
representative also stated that he had never received an IDR for
these years. Ward offered to give to him the IDR that she had
prepared for the April 23, 1996, meeting, but petitioners’
representative refused to accept it.
The next day, June 27, 1996, respondent issued a notice of
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