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1989, Mr. Berg called Agent Mazon to cancel the proposed August
appointments.
On August 28, 1989, Agent Mazon called Mr. Berg and proposed
a conference with petitioner Rosalia Gorgie for September 21,
1989. On September 21, 1989, Agent Mazon met with Mr. Berg and
submitted IDR 4, requesting bank records for 1986 (which were the
subject of IDR 2, but which were still not received) as well as
other bank records and documentation supporting alleged loan
repayments and information on how petitioners arrived at their
income in their returns. Because of her poor health, Rosalia
Gorgie did not attend the September 21, 1989, meeting.
By letter dated October 28, 1989, Mr. Berg stated that
petitioners were unable to locate certain requested bank records.
Mr. Berg then requested that a 30-day letter be issued.
Because petitioner did not provide all requested bank
statements, Agent Mazon had to obtain from NERC copies of NERC
checks that were deposited into petitioner's bank accounts. In
July, September, and November of 1989, Agent Mazon compiled NERC
check summaries for the purpose of determining the total amounts
of NERC checks deposited into Frank Gorgie's accounts.
On December 4, 1989, Agent Mazon discussed the case with her
manager, Ley Malilay. Agent Mazon and Mr. Berg spoke on December
6, 1989, and scheduled an appointment for December 8, 1989. On
December 6, 1989, petitioners' 1988 tax year was opened for
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