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Petitioner’s Merrill Lynch account was not mentioned to Mr.
Rangel, and he was not provided records for petitioner’s Merrill
Lynch accounts.
In an Information Document Request (IDR) dated January 31,
1992, Mr. Rangel asked petitioner to provide, inter alia, all
bank statements, canceled checks, and stockbrokers’ statements
for 1988, 1989, and 1990. In an IDR dated July 2, 1992, Mr.
Rangel asked petitioner to provide all Merrill Lynch statements
for 1988, 1989, and 1990. Neither petitioner nor her
representatives produced any Merrill Lynch records in response to
the IDRs.
On April 10, 1992, Mr. Reiter and respondent executed a Form
872-A, Special Consent to Extend the Time to Assess Tax,
indefinitely extending the period of assessment for petitioner’s
1988 tax year.
On July 31, 1992, Mr. Rangel met with Mr. Reiter at Mr.
Reiter’s office. Mr. Rangel asked Mr. Reiter why he had not been
provided the Merrill Lynch records. Mr. Reiter stated that he
was not the problem. Mr. Reiter, on his own initiative, placed a
call to petitioner on his speakerphone. During this call,
petitioner told Mr. Reiter to do what he could, but that Mr.
Rangel was not going to get her Merrill Lynch records.
Petitioner was unaware that Mr. Rangel heard what she was saying
to Mr. Reiter.
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