- 46 -
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
Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 NextLast modified: May 25, 2011