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1991 and 1992. Mr. DiBernardo asked Ms. Martin to send him
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 maintained during those years,
and (3) the 1991-1992 deposits analysis that Ms. Martin had
prepared. Ms. Martin complied with Mr. DiBernardo’s requests.
Sometime after Mr. DiBernardo began representing petitioner
and Ms. Brodsky with respect to respondent’s examination of their
joint returns for 1991 and 1992, Ms. Martin attempted to schedule
a conference with petitioner, Ms. Brodsky, and Mr. DiBernardo.
Ms. Martin scheduled three separate conferences with petitioner,
Ms. Brodsky, and Mr. DiBernardo, each of which petitioner can-
celed 1 to 2 days prior to the date on which it was scheduled to
take place. Consequently, Ms. Martin issued summonses on behalf
of respondent to petitioner and Ms. Brodsky in order to compel
them to meet with her. Ms. Martin served the summons on peti-
tioner at his home and sent a copy to Mr. DiBernardo. After
having been served with the summons, petitioner informed Ms.
Martin that he was not able to meet with her on the date stated
in the summons and did not suggest another date on which he was
able to meet with her. Ms. Martin rescheduled the conference
date listed in the summons in order to accommodate petitioner.
Pursuant to respondent’s summonses to petitioner and Ms.
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