Zinovy Brodsky - Page 98




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          she informed them that she did not believe that the limited books           
          and records that petitioner had provided to her substantiated the           
          various items that were claimed in the joint returns for 1987               
          through 1990.  At that conference, Ms. Rodegeb made certain                 
          recommendations to petitioner with respect to the types of books            
          and records that he should maintain.  Ms. Rodegeb also informed             
          both petitioner and Mr. Sutton at the October 1991 conference               
          that, after she concluded the examination of the joint returns of           
          petitioner and Ms. Brodsky for taxable years 1987 through 1990,             
          she intended to recommend that respondent issue a so-called                 
          inadequate records notice (inadequate records notice) to them,              
          which would require that they show respondent that they were                
          keeping adequate books and records.                                         
               Sometime after the October 1991 conference, Ms. Rodegeb met            
          with her manager regarding, inter alia, her recommendation that             
          respondent issue an inadequate records notice to petitioner and             
          Ms. Brodsky.  The only effect of issuing such a notice would have           
          been to trigger an examination of the joint returns of petitioner           
          and Ms. Brodsky for taxable years after 1990, the last year                 
          examined by Ms. Rodegeb.  Since Ms. Rodegeb’s manager had already           
          concluded that respondent should examine those joint returns, it            
          was decided that respondent would not issue an inadequate records           
          notice to petitioner and Ms. Brodsky at the conclusion of respon-           
          dent’s examination of their joint returns for taxable years 1987            






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