Sam F. and Ingrid D. Ford - Page 7

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               copies thereof, must be purged from the Criminal                       
               Investigation Division files prior to closing in turn                  
               to the Chief, Examination Division.                                    
               Administrative Proceedings Against Petitioner                          
               At some point during 1997, Marco I. Minervini of                       
          respondent's Appeals Office in New York transmitted by facsimile            
          a file copy of a so-called 30-day letter to Sylvia McGee of the             
          Manhattan Examination Division.  The 30-day letter was dated May            
          21, 1996, and was addressed to petitioners.  It proposed                    
          adjustments to their taxes for the year 1986.  The letter advised           
          that petitioners would have 30 days to have respondent's proposed           
          adjustments reviewed in respondent's Appeals Office.  It                    
          contained two proposed upward adjustments for petitioners' income           
          in 1986–-one for $834,857 in short-term capital gains and the               
          other for $4,249,563 in long-term capital gains.  An accompanying           
          explanation stated that the adjustments in question were "as set            
          forth in Government exhibit #3, 90-CR-777-1."  Additionally, the            
          30-day letter included the following identical explanations                 
          regarding each of the two proposed adjustments:  "These exclude             
          transactions in the names of Ingrid Doorn and Marc Ford, either             
          reported by taxpayers or reported elsewhere (by Marc Ford)."                
          Marc Ford is petitioner's son.                                              
               Thereafter, respondent's District Counsel in Manhattan                 
          (District Counsel) sent a memorandum dated October 13, 1998, to             
          the Chief of Manhattan Appeals, with an attention line to M.                

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