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consideration of beginning cash, nor any likely source of
income."
The petitions were filed on behalf of petitioners by Towner
Leeper, who remains counsel of record in these cases.
In connection with the adjustments resulting from Agent
Red's review of the various bank accounts, the positions taken by
respondent in her answers are the positions that respondent took
in the notices of deficiency; that is, unexplained bank deposits
represent taxable income to the depositor.
After the cases were docketed, they were assigned to Appeals
Officer Gene Hill. Sharon Haddad (Haddad), a certified public
accountant, was hired by petitioners in connection with Appeals
Officer Hill's consideration of the cases. Petitioners requested
that the Court continue the cases from a scheduled trial session
so that Haddad would have additional time to complete an analysis
of Agent Red's examination prior to meeting with Appeals Officer
Hill. Haddad eventually completed her analysis and prepared
several reports that focused on the adjustments made to the
Abrahams' income. Her analysis and reports were limited to the
year 1987. One of the reports (the transfer report) that she
prepared contained a side-by-side comparison of the numerous bank
account transactions between Abraham and Lawrence. The transfer
report did little more than reproduce certain of Abraham's
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