Carl Dimichele and Eileen Dimichele - Page 24

                  We have several difficulties with petitioner's                      
             testimony.  First, on two occasions, respondent propounded               
             the following interrogatory to petitioner and her husband:               

                       78.  Indicate all inheritances that the                        
                  petitioners or their children received in their                     
                  lifetime.  Also if applicable, indicate the                         
                  following:                                                          
                            (a)  Who the inheritance was left to;                     
                            (b)  Who the inheritance was left from;                   
                            (c) Indicate the approximate value of                     
                                 the inheritance and the date that                    
                                 it was received;                                     
                            (d) Indicate if an inheritance tax                        
                                 return was ever filed.  If                           
                                 applicable, indicate the date                        
                                 and location of where it was                         
                                 filed;                                               

                            (e) If an inheritance tax return was                      
                                 not filed explain why;                               
                            (f) Indicate the exact asset that                         
                                 was gifted.  i.e. cash,                              
                                 property, jewelry etc.                               

             In response to both interrogatories, petitioner and her                  
             husband responded, "No".                                                 
                  Second, petitioner's testimony about the jewelry is                 











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