- 80 - 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.Page: Previous 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 Next
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