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