Zinovy Brodsky - Page 100




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          Sometime after the May 1994 conference, Ms. Martin wrote Mr.                
          Sutton a letter (Ms. Martin’s second 1994 letter) in which she              
          indicated that she believed that petitioner and/or Ms. Brodsky              
          had maintained accounts during 1991 in addition to the accounts             
          about which petitioner had previously informed her.  Ms. Martin             
          explained in Ms. Martin’s second 1994 letter why she held that              
          belief and enclosed a second written request for 1991 documents             
          with that letter.  That second request asked petitioner and Ms.             
          Brodsky to provide Ms. Martin within one month all records                  
          pertaining to any such additional accounts.  Ms. Martin received            
          no response to Ms. Martin’s second 1994 letter or to her second             
          written request for 1991 documents.  Consequently, Ms. Martin               
          issued summonses on behalf of respondent to the banks at which              
          she knew or believed petitioner and/or Ms. Brodsky had maintained           
          accounts during 1991.                                                       
               Sometime in August 1994, respondent, through Ms. Martin,               
          decided to commence an examination of the 1992 joint return of              
          petitioner and Ms. Brodsky.  Around that time, Ms. Martin mailed            
          Mr. Sutton a letter and a written request for documents for their           
          taxable year 1992 (collectively, the August 1994 letter).  The              
          August 1994 letter asked that petitioner and Ms. Brodsky provide            
          Ms. Martin with all records with respect to the accounts that one           
          or both of them had maintained during 1992.  Ms. Martin received            
          no response to the August 1994 letter.  Consequently, Ms. Martin            






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