Zinovy Brodsky - Page 139




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          which they canceled.  Mr. Oliveras30 asked the representative of            
          petitioner and Ms. Brodsky with respect to respondent’s examina-            
          tion of their 1993 joint return whether there were any nontaxable           
          sources for any of the deposits reflected in the deposits analy-            
          sis prepared by respondent with respect to 1993.  Although that             
          representative suggested to Mr. Oliveras that there might be                
          certain nontaxable items, that representative did not specify               
          which 1993 deposits are nontaxable, nor did such representative             
          provide Mr. Oliveras with any documentation or other information            
          showing that certain of such deposits are not taxable.                      
               As described in the Court’s Order dated December 30, 1999,             
          petitioner remained generally uncooperative in working with                 
          respondent in the stipulation process in preparing this case for            
          the scheduled trial on October 19, 1999.  It was not until the              
          Court intervened at the request of respondent’s counsel that                
          petitioner finally participated in the stipulation process with             
          respondent’s counsel on October 13, 1999.  After the trial in               
          this case took place and after petitioner filed in mid-December             
          1999 a motion to open the record and a motion for leave to allow            
          offer of proof, petitioner provided certain documentation and               
          information to respondent that he had not previously provided,              
          which enabled respondent to conclude that certain deposits into             
          petitioner’s accounts that remained at issue, including certain             
          payments against the balances due on petitioner’s credit ac-                

               30Mr. Oliveras completed respondent’s examination of the               
          1993 joint return of petitioner and Ms. Brodsky after Ms. Martin            
          had commenced and worked on that examination.                               




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