William C. Eberhardt, Jr. and Susan A. Eberhardt - Page 5

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          not submit any documents pertaining to Mr. Eberhardt's medical              
          expenses or any of the other documents requested in the IDR.                
               On March 10, 1998, respondent sent petitioners a second IDR            
          regarding petitioners' medical expenses, casualty or theft loss,            
          and Schedule C income and expenses.  On May 2, 1998, petitioners            
          submitted to respondent documentation pertaining to their claimed           
          casualty or theft loss, which was related to petitioners' pension           
          plan.  They did not submit any medical expense or Schedule C                
          documentation.                                                              
               On May 24, 1998, petitioners sent respondent a copy of their           
          1993 Federal income tax return and a copy of a letter respondent            
          sent to petitioners resolving an audit of their 1993 tax year.              
          After reviewing petitioners' 1993 return, respondent's examiner             
          narrowed the scope of the audit of petitioners' 1995 return to              
          their medical expenses and the pension-related casualty or theft            
          loss.                                                                       
               On May 27, 1998, respondent mailed to petitioners a report             
          proposing adjustments to petitioners' medical expense deductions            
          and the pension-related casualty or theft loss.  Petitioners had            
          invested in a self-directed IRA with First Pension Corporation              
          (First Pension).  In April 1994, First Pension filed for                    
          bankruptcy, and the accounts of their investment trustee, Summit            
          Trust Company, were frozen.  At the time of the bankruptcy                  
          filing, petitioners' account contained a 5-acre parcel of land              






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