Frank H. and Marla C. Black - Page 4

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               Petitioners filed timely joint Federal income tax returns              
          for taxable years 1991 and 1992.  Mr. Black prepared a draft of             
          the 1991 joint return and took it to a certified public                     
          accountant (C.P.A.) for review.  The C.P.A. made some minor                 
          corrections, then used the data shown on the draft to create a              
          computer-generated 1991 joint return.  The 1992 joint return was            
          prepared by an accountant based upon computer printouts of income           
          and expenses and oral information provided by Mr. Black.                    
               Internal Revenue Service (IRS) Revenue Agent Margaret                  
          McCarter (Agent McCarter) was assigned to the examination of                
          petitioners’ joint returns for the taxable years 1991 and 1992.             
          Agent McCarter’s initial contact with Mr. Black occurred on                 
          May 11, 1993, when she mailed him a letter advising him that                
          his 1991 income tax return was being examined and scheduling an             
          appointment for May 24, 1993.                                               
               Mr. Black refused to meet with Agent McCarter.  As a result,           
          most of Agent McCarter’s later contacts were with the                       
          representatives to whom Mr. Black delegated powers of attorney.             
               On May 26, 1994, Agent McCarter referred Mr. Black’s case to           
          the IRS Criminal Investigation Division.                                    
               On October 18, 1994, IRS Special Agent Dennis O’Dell (Agent            
          O’Dell) and Agent McCarter went to meet with Mr. Black at his               
          place of business in Charlotte, North Carolina.  After arriving,            
          they introduced themselves to Mr. Black, and Agent O’Dell                   

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