Zinovy Brodsky - Page 105




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          Brodsky to another revenue agent, Rafael Oliveras (Mr. Oliveras),           
          who completed that examination.  Mr. Oliveras, inter alia,                  
          reviewed the documents that respondent received in response to              
          the summonses issued to the banks at which petitioner and/or Ms.            
          Brodsky had maintained accounts during 1993.  In connection with            
          his examination of the 1993 joint return of petitioner and Ms.              
          Brodsky, Mr. Oliveras had a number of telephonic conferences with           
          their authorized representative (representative).  Mr. Oliveras             
          asked that representative whether during 1993 certain of the                
          deposits into the accounts of petitioner and/or Ms. Brodsky                 
          represented items that are not taxable.  Although the representa-           
          tive of petitioner and Ms. Brodsky suggested to Mr. Oliveras that           
          there might be certain nontaxable items, that representative did            
          not specify which deposits during 1993 are nontaxable, nor did              
          such representative provide Mr. Oliveras with any documentation             
          or other information showing that certain of such deposits are              
          nontaxable.  The representative of petitioner and Ms. Brodsky               
          never informed Mr. Oliveras that petitioner had obtained any                
          loans during 1993.                                                          
               In addition to working on the examination of the 1993 joint            
          return of petitioner and Ms. Brodsky, Mr. Oliveras conducted an             
          examination of Form 1065 of MZ Trading for 1993.  In connection             
          with that latter examination, Mr. Oliveras performed a bank                 
          deposits analysis of MZ Trading’s bank accounts for 1993 and                






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