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schedule a meeting with petitioner and Ms. Brodsky, Ms. Martin
attempted several times to reach Mr. Sutton by telephone and also
sent him another letter. Mr. Sutton did not respond to those
telephone calls or that letter.
Sometime in December 1994, Ms. Martin received a power of
attorney authorizing Elizabeth Schwiff (Ms. Schwiff) to represent
petitioner and Ms. Brodsky with respect to respondent’s examina-
tion of their joint returns for 1991 and 1992. Thereafter, Ms.
Martin telephoned Ms. Schwiff. During that telephone call, Ms.
Schwiff asked Ms. Martin to mail her copies of (1) all of the
requests for documents that Ms. Martin had issued with respect to
1991 and 1992, (2) the bank statements that Ms. Martin had
reviewed for those years regarding accounts that petitioner
and/or Ms. Brodsky had maintained during those years, and (3) the
1991-1992 deposits analysis that Ms. Martin had prepared. Ms.
Martin complied with Ms. Schwiff’s requests. Sometime after Ms.
Martin mailed Ms. Schwiff the copies of all of the documents that
Ms. Schwiff had requested, Ms. Schwiff informed Ms. Martin that
petitioner and Ms. Brodsky intended to organize their records.
Thereafter, Ms. Martin had no further contact with Ms. Schwiff.
Sometime between the end of May 1995 and the beginning of
July 1995, respondent received a power of attorney authorizing
Mr. DiBernardo to represent petitioner and Ms. Brodsky with
respect to respondent’s examination of their joint returns for
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