- 45 -
Brodsky, they met with Ms. Martin on November 29, 1995 (November
1995 conference). At that conference, petitioner and Ms. Brodsky
made certain statements regarding the sources of certain deposits
that were made into one or more of their accounts during 1991 and
1992 but did not provide any documentation to corroborate those
statements. After the November 1995 conference, Ms. Martin asked
petitioner and Ms. Brodsky to provide her with documentation to
corroborate the statements that they had made at that conference
regarding the sources of certain deposits that were made into one
or more of their accounts during 1991 and 1992. Ms. Martin
received no documents in response to that request. Thereafter,
Ms. Martin scheduled several more conferences with petitioner and
Ms. Brodsky, all of which they canceled.
Sometime early in 1996, respondent, through Ms. Martin,
commenced an examination of the joint return of petitioner and
Ms. Brodsky for 1993, asked them for documents relating to that
year, received no response to that request, and issued summonses
on behalf of respondent to the banks at which petitioner and/or
Ms. Brodsky had maintained accounts during 1993. Sometime in the
spring of 1996, Ms. Martin’s manager directed her to complete the
examination of the 1991 and 1992 joint returns of petitioner and
Ms. Brodsky.
Thereafter, respondent transferred responsibility for the
examination of the 1993 joint return of petitioner and Ms.
Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 NextLast modified: May 25, 2011