- 26 - Federal checking account. Mr. Bruno did not know petitioner was cashing and exchanging checks until testimony was given before the grand jury on May 25, 1990. Throughout the course of Ms. Davis' examination, petitioner never told Mr. Bruno that the income figures he gave to him for 1987 and 1988 were incorrect. Similarly, throughout the ensuing criminal investigation in which Mr. Bruno assisted in the representation of petitioner, Mr. Bruno was never told that the income figures were incorrect. Mr. Bruno subsequently furnished Ms. Davis with information which attempted to establish the nontaxable nature of $100,000 of the understatement. Since the amount of $150,000 still remained unexplained, Ms. Davis determined that it represented unreported income. She then explained that the Service likely would want to begin an examination of petitioners' 1988 income tax return. After consulting with her supervisor, Ms. Davis told Mr. Bruno that the subsequent year examination would be commenced. In March 1990, two attorneys, Mr. White and Mr. Gray, representing petitioners with a valid power of attorney, went to Ms. Davis' office and requested that they meet with her and her manager. Mr. White thought Ms. Davis had completed the examination for both 1987 and 1988, although she had not begun the examination for 1988. Although the then proposed deficiency for 1987 was approximately $50,000, Mr. White stated thatPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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