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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 of
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