- 79 - returns for the years at issue in that, inter alia, he provided respondent with relatively little documentation and other infor- mation. In this connection, after Ms. Martin completed the 1991- 1992 deposits analysis, she mailed a copy of it to Mr. Sutton along with another written request for documents and a written request that petitioner 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. Thereaf- ter, Ms. Martin unsuccessfully attempted to meet with petitioner and Ms. Brodsky, and Ms. Martin was forced to issue summonses to them in order to compel them to meet with her. After reschedul- ing the date of the meeting stated in respondent’s summonses in order to accommodate petitioner, Ms. Martin met with petitioner and Ms. Brodsky on November 29, 1995. Although petitioner and Ms. Brodsky made certain statements at that meeting regarding the sources of certain deposits that were made into one or more of their accounts during 1991 and 1992, they did not provide any documentation to corroborate those statements. After the Novem- ber 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 ac- counts 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 ofPage: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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