Dwight L. McKenna and Beverly S. McKenna - Page 20

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            power of attorney form had been filed, she asked that Mr. Bruno                             
            contact her.  He telephoned her the same day, and they confirmed                            
            an appointment date.                                                                        
                  On October 5, 1989, Ms. Davis sent a letter to petitioners                            
            confirming the initial appointment on October 27, 1989.  To that                            
            letter, she attached an Information Document Request, Form 4564,                            
            (hereafter IDR) dated October 5, 1989.  The IDR requested, among                            
            other items, all of the petitioners' bank statements, canceled                              
            checks, and duplicate deposit slips, as well as information with                            
            respect to invested funds.  Petitioner provided Mr. Bruno with a                            
            copy of the letter and the IDR.                                                             
                  When Ms. Davis first met with Mr. Bruno, petitioner was not                           
            present.  Mr. Bruno appeared to have a limited knowledge of and                             
            records for petitioner's medical practice and the income and                                
            expenses claimed for 1987 and 1988.  However, he was familiar                               
            with Mrs. McKenna's newspaper business and made the records                                 
            available.  After examining the newspaper business records, Ms.                             
            Davis determined that each Schedule C for the newspaper for 1987                            
            and 1988 was correct and no adjustment was made.  Similarly,                                
            after examining the information regarding petitioners' rental                               
            property and the income derived therefrom, Ms. Davis determined                             
            that the income was correctly reported and there were no                                    
            adjustments with respect to the rental property.                                            








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