- 39 - 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 1987Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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