- 41 - 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. MartinPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011