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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
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