Morton Zuckerman - Page 9

                                        - 9 -                                         



               Dickoff requested documents from petitioner relating to the            
          sources of unexplained deposits, but petitioner did not provide             
          them.  Petitioner did not apprise Dickoff of any loans or                   
          inheritances that might have accounted for some of the deposits.            
          Dickoff did not attempt to obtain copies of the Zuckermans'                 
          canceled checks from the banks to ascertain whether they may have           
          made or received any loans in 1987.  Owing, inter alia, to                  
          petitioner's refusal to extend the limitations period for                   
          assessment, Dickoff concluded that the time remaining to complete           
          his investigation and analysis was insufficient.                            
               In the notice of deficiency issued to petitioner and                   
          Mrs. Zuckerman on March 3, 1993, respondent increased the                   
          Zuckermans' gross income for 1986 by the $65,000 that petitioner            
          had misappropriated from Lawrence, increased their gross income             
          for 1987 by the $66,230 of unexplained bank deposits, increased             
          their gross income for both years to reflect amounts of                     
          unreported interest and dividends shown on Forms 1099, and                  
          disallowed in whole or in part certain deductions claimed on                
          Schedules A and C for interest, taxes, and other expenses which             
          the Zuckermans had not adequately substantiated.  A petition                
          signed in both spouses' names was timely filed.                             
               On August 16, 1994, the Court granted a motion by respondent           
          to compel production of documents and answers to interrogatories            
          relating to all substantive issues in the case and advised the              



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011