Dennis E. Runkle and Debra A. Runkle - Page 10

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          a meeting on August 26, 1994, Mr. Runkle responded that he was              
          unavailable to meet on the scheduled date.  Mr. Runkle did not              
          propose an alternative date.  Similarly, when Revenue Agent                 
          Andrews issued an examination letter to Mrs. Runkle for 1991,               
          1992, and 1993, Mrs. Runkle neither appeared at the scheduled               
          appointment nor rescheduled the appointment.                                
               In response to the revenue agent’s summons directing Mrs.              
          Runkle to produce her books and records for 1991, 1992, and 1993,           
          Mr. Runkle advised Revenue Agent Andrews that Mr. Runkle would              
          accompany Mrs. Runkle to her summons appointment.  Four witnesses           
          who refused to disclose their identities also attended the                  
          summons conference with petitioners.  At petitioners’ request,              
          both petitioners and Revenue Agent Andrews taped the summons                
          conference.  At the summons conference, Mrs. Runkle demanded that           
          Revenue Agent Andrews provide her with his personal residence               
          address as a prerequisite to her complying further with the                 
          summons.  When Revenue Agent Andrews refused to provide his                 
          personal address, Mrs. Runkle advised him that the summons                  
          conference was done as far as she was concerned.  She also                  
          advised Revenue Agent Andrews that she did not bring any books              
          and records with her.                                                       
               At the summons conference, Mr. Runkle demanded that Revenue            
          Agent Andrews provide him with the Code section that makes him              
          liable for taxes, to which Revenue Agent responded that section             

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