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1989, petitioner responded to Agent Mazon's letter by telephone,
informing her that John Berg had a power of attorney from
petitioners.
On May 24, 1989, Mr. Berg called Agent Mazon and left a
message, stating that he would be back on May 28, 1989. After
trading telephone messages, on May 31, 1989, Agent Mazon spoke
with Mr. Berg and scheduled an appointment for June 27, 1989. On
June 21, 1989, Mr. Berg called Agent Mazon to reschedule the
appointment for July 5, 1989.
On July 5, 1989, Agent Mazon met with Mr. Berg and
petitioner at Mr. Berg's office. At the meeting, petitioner
provided some, but not all, of the requested bank records.
Petitioner did not provide complete bank records for two savings
and loan accounts, which prompted Agent Mazon to tender IDR 2
requesting those documents. They scheduled a second appointment
for July 6, 1989.
On July 6, 1989, Agent Mazon met with Mr. Berg at Mr. Berg's
office. Agent Mazon tendered IDR 3 asking for additional bank
and nonbank records relating to petitioners.
On July 14, 1989, Agent Mazon called Mr. Berg and left a
message requesting an appointment with petitioner Rosalia Gorgie
and petitioners' return preparer. Agent Mazon requested that the
appointment take place on August 1 and 2, 1989. On July 27,
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