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she informed them that she did not believe that the limited books
and records that petitioner had provided to her substantiated the
various items that were claimed in the joint returns for 1987
through 1990. At that conference, Ms. Rodegeb made certain
recommendations to petitioner with respect to the types of books
and records that he should maintain. Ms. Rodegeb also informed
both petitioner and Mr. Sutton at the October 1991 conference
that, after she concluded the examination of the joint returns of
petitioner and Ms. Brodsky for taxable years 1987 through 1990,
she intended to recommend that respondent issue a so-called
inadequate records notice (inadequate records notice) to them,
which would require that they show respondent that they were
keeping adequate books and records.
Sometime after the October 1991 conference, Ms. Rodegeb met
with her manager regarding, inter alia, her recommendation that
respondent issue an inadequate records notice to petitioner and
Ms. Brodsky. The only effect of issuing such a notice would have
been to trigger an examination of the joint returns of petitioner
and Ms. Brodsky for taxable years after 1990, the last year
examined by Ms. Rodegeb. Since Ms. Rodegeb’s manager had already
concluded that respondent should examine those joint returns, it
was decided that respondent would not issue an inadequate records
notice to petitioner and Ms. Brodsky at the conclusion of respon-
dent’s examination of their joint returns for taxable years 1987
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