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                         
                            (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                         

                            (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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