Zinovy Brodsky - Page 138




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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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