Padgett Coventry Price - Page 14

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               In August 1992, Jackie Anderson, C.P.A., telephoned Mr.                
          Rangel and advised him that she was representing petitioner.                
          Although she told Mr. Rangel that she would provide the documents           
          he had requested, Ms. Anderson did not.                                     
               On November 20, 1992, Mr. Rangel served a summons on Merrill           
          Lynch for petitioner’s records.  Mr. Rangel sent a notice copy of           
          this summons to petitioner.  Petitioner contacted Merrill Lynch,            
          spoke to Christopher Eng in the company’s compliance department,            
          and tried to dissuade him from complying with the IRS summons.              
          After speaking to petitioner, Mr. Eng contacted Mr. Rangel and              
          asked whether Merrill Lynch was required to comply with the                 
          summons.  Mr. Rangel advised Mr. Eng that the IRS would take                
          enforcement action against Merrill Lynch if it did not produce              
          the requested records.  On or about December 22, 1992, Mr. Eng              
          forwarded petitioner’s Merrill Lynch statements to Mr. Rangel.              
               After receiving the Merrill Lynch statements, Mr. Rangel               
          discovered checks written to petitioner out of the client trust             
          account and deposited in her Merrill Lynch account.  Mr. Rangel             
          asked petitioner or her representative about several deposits               
          made into her Merrill Lynch account during the years in issue,              
          including the $25,000 deposit made in 1988.  Petitioner or her              
          representative told Mr. Rangel that the $25,000 deposit was an              
          inheritance from the estate of Mr. Ludlow’s mother, who died in             
          1984.                                                                       






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