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issued summonses on behalf of respondent to the banks at which
she knew or believed petitioner and/or Ms. Brodsky had maintained
accounts during 1992.
Based on certain information contained in the documents that
Ms. Martin received as a result of the summonses that respondent
issued, she concluded that petitioner and/or Ms. Brodsky had
maintained additional accounts during 1991 and 1992 that they had
failed to disclose to her. Consequently, Ms. Martin issued
summonses on behalf of respondent to obtain information with
respect to those additional accounts.
Based on certain information contained in the documents that
Ms. Martin had received as a result of the summonses that respon-
dent issued, she prepared a spreadsheet for 1991 and 1992. That
spreadsheet showed each of the deposits that had been made into
each of the accounts that Ms. Martin knew petitioner and/or Ms.
Brodsky had maintained during those years, as well as the date
and the amount of each such deposit (1991-1992 deposits analy-
sis). After Ms. Martin completed the 1991-1992 deposits analy-
sis, she mailed a copy of it to Mr. Sutton along with another
written request for documents and a written request that peti-
tioner and Ms. Brodsky identify any item listed in that analysis
which they believed to be nontaxable and provide her with records
to verify the source of any such item. Ms. Martin did not
receive any response to those requests. Thereafter, in order to
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