Marvin L. Barmes and Barbara J. Barmes - Page 5

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          Trust and Sandbar Real Estate Trust as the trusts.)  The re-                
          quested trust documents with respect to each of those trusts that           
          the October 13, 2000 Order directed petitioners to produce                  
          included, inter alia, the trust agreement with any amendments               
          from tax year 1995 to the present, the certificates of beneficial           
          interest issued by the trust during or otherwise effective for              
          tax year 1995, any agreements between the trust and either                  
          petitioner or both petitioners with respect to the use of the               
          trust assets by either or both of them, any compensation agree-             
          ments between petitioner Marvin Barmes (Mr. Barmes) and the trust           
          for tax years 1995 to the present, all capital unit certificates            
          issued by the trust from tax year 1996 to the present, all trust            
          accounting books and records for the period beginning with the              
          trust’s purported creation through December 31, 1995, all trust             
          documents pertaining to distributions from the trust for the                
          period beginning with the trust’s purported creation to the                 
          present, and certain trust bank account information.                        
               Petitioners objected on the following grounds (petitioners’            
          objections) to the production of the documents requested in                 
          respondent’s request for production of documents:  (1) Relevancy            
          with respect to any documents requested regarding Sandbar Real              
          Estate Trust; (2) petitioners’ lack of custody, possession, or              

          not consider to be documents of Sandbar Wholesale Trust and/or              
          Sandbar Real Estate Trust.                                                  

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