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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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