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return provided in pertinent part as follows:
Line 2, Adjustments to Income:
Expenses in the amount of $91,920.00 are claimed in
connection with legal fees and custodian fees paid for
the purpose of protecting and preserving existing busi-
ness assets, business income, professional reputation
and professional employment.
At a time not disclosed by the record before July 6, 1995,
respondent initiated an examination of the respective joint
returns for the taxable years at issue (examination of the tax-
able years at issue). On July 6, 1995, petitioner and Mr.
Monsour executed Form 2848, Power of Attorney and Declaration of
Representative, in which they appointed Mr. Winschel as their
attorney-in-fact with respect to that examination.
At a time not disclosed by the record after the examination
of the taxable years at issue began, respondent’s Appeals Office
(Appeals Office) began consideration of those years. Mr.
Winschel continued to represent petitioner and Mr. Monsour at the
Appeals Office.
At a time not disclosed by the record before December 16,
1997, respondent issued to petitioner and Mr. Monsour a notice
with respect to the taxable years at issue (notice for the tax-
able years at issue).9 In that notice, respondent made determina-
tions for one or more of the taxable years 1989, 1991, 1992, and
9The notice for the taxable years at issue is not part of
the record in the instant case. The record does not establish
whether respondent made determinations in that notice relating to
any matters other than those discussed herein.
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