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Petitioner paid Annette Pores an annual salary of $8,000 for
clerical services rendered for the taxable years 1987, 1988,
1989, and 1990.
Petitioner maintained records of her finances in an office
located at the Dock Hollow property.
On or about September 1, 1988, the United States filed suit
to collect the deficiencies determined by the Tax Court in
Freidus v. Commissioner, T.C. Memo. 1979-507, in which Mr.
Freidus was the petitioner. During 1989, the United States
sought to depose Jacob Freidus and to examine documents in his
possession that described his income and assets. Mr. Freidus
resisted the efforts of the United States and the United States
was forced to seek the District Court's assistance in conducting
discovery. The United States also sought documents and
deposition testimony from petitioner.
As a result of the District Court's order and subpoena
issued to petitioner, three file cabinets and 43 boxes of records
were transferred from her home and delivered to the office of her
attorney beginning on February 23, 1990, at a rate of no more
than two or three boxes per week. These records were copied and
delivered to the United States, except for approximately 1,900
documents which petitioner claimed were privileged under the
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