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through 1990.
At the conclusion of respondent’s examination of the 1990
joint return of petitioner and Ms. Brodsky, respondent did not
make any determinations with respect to the gross receipts
reported in Schedule C of that return.
Around March 1994, respondent assigned another revenue
agent, Theresa Martin (Ms. Martin), to examine the 1991 joint
return of petitioner and Ms. Brodsky. In early March 1994, Ms.
Martin mailed to petitioner and Ms. Brodsky a letter and a
written request for 1991 documents (collectively, the March 1994
letter). The March 1994 letter asked petitioner and Ms. Brodsky
to provide her with all of the statements, checks, and bank
documents for all of the bank accounts, both personal and busi-
ness, over which one or both of them had signature authority. In
response to the March 1994 letter, petitioner provided Ms. Martin
with certain statements and canceled checks with respect to
petitioner’s UVW account.
Sometime between the date in early March 1994 on which Ms.
Martin sent the March 1994 letter to petitioner and Ms. Brodsky
and the date in May 1994 on which Ms. Martin first met with
petitioner and Ms. Brodsky (May 1994 conference), petitioner
executed a power of attorney that authorized Mr. Sutton to
represent him with respect to respondent’s examination of the
1991 joint return that petitioner and Ms. Brodsky had filed.
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