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Mr. Laubach issued a subpoena to Monsour Medical Center in order
to determine whether there was any omitted interest income with
respect to that entity. On June 8, 1998, Hugh E. Teitelbaum (Mr.
Teitelbaum), legal counsel for Monsour Medical Center, responded
to that subpoena and sent a copy of his response to petitioner.
Mr. Monsour met with Mr. Winschel several times to discuss
the issues in the case for the taxable years at issue.13 Two of
those meetings were dinner meetings (dinner meetings) that took
place at the residence of petitioner and Mr. Monsour. Petitioner
was present at those dinner meetings.
Petitioner knew that for two of the three taxable years
1991, 1992, and 1993 respondent made a determination of omitted
income relating to petitioner’s law practice bank account in an
amount between $8,000 and $10,000. (We shall refer collectively
to those two determinations as determinations relating to peti-
tioner’s law practice bank account.) At petitioner’s request,
Mr. Winschel conceded the determinations relating to petitioner’s
law practice bank account.
Mr. Laubach met with Mr. Winschel several times to discuss
settling the case for the taxable years at issue. Mr. Laubach
spent a lot of time in an attempt to reach a settlement of that
13The record does not disclose how many times Mr. Monsour
met in person with Mr. Winschel to discuss the case for the
taxable years at issue or how many times, if any, they discussed
that case over the telephone and/or in written correspondence or
electronic mail.
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