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Sometime after the May 1994 conference, Ms. Martin wrote Mr.
Sutton a letter (Ms. Martin’s second 1994 letter) in which she
indicated that she believed that petitioner and/or Ms. Brodsky
had maintained accounts during 1991 in addition to the accounts
about which petitioner had previously informed her. Ms. Martin
explained in Ms. Martin’s second 1994 letter why she held that
belief and enclosed a second written request for 1991 documents
with that letter. That second request asked petitioner and Ms.
Brodsky to provide Ms. Martin within one month all records
pertaining to any such additional accounts. Ms. Martin received
no response to Ms. Martin’s second 1994 letter or to her second
written request for 1991 documents. Consequently, Ms. Martin
issued summonses on behalf of respondent to the banks at which
she knew or believed petitioner and/or Ms. Brodsky had maintained
accounts during 1991.
Sometime in August 1994, respondent, through Ms. Martin,
decided to commence an examination of the 1992 joint return of
petitioner and Ms. Brodsky. Around that time, Ms. Martin mailed
Mr. Sutton a letter and a written request for documents for their
taxable year 1992 (collectively, the August 1994 letter). The
August 1994 letter asked that petitioner and Ms. Brodsky provide
Ms. Martin with all records with respect to the accounts that one
or both of them had maintained during 1992. Ms. Martin received
no response to the August 1994 letter. Consequently, Ms. Martin
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