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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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