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control over the documents requested in respondent’s request for
production of documents, if any such documents existed;
(3) relevancy with respect to any documents requested for any tax
periods other than 1995; and (4) the Fifth Amendment. In the
October 13, 2000 Order, we considered and rejected each of the
first three of petitioners’ objections. In that Order, we
considered and (1) sustained petitioners’ Fifth Amendment claim
insofar as it related to the production of petitioners’ personal
documents and (2) rejected that claim insofar as it related to
the production of the requested trust documents.
In the October 13, 2000 Order, we cautioned petitioners that
we would be inclined to impose sanctions under Rule 104(c) in the
event that petitioners did not fully comply with the provisions
of that Order requiring them to produce to counsel for respondent
the requested trust documents.
On October 18, 2000, petitioners filed a motion to recon-
sider the October 13, 2000 Order (petitioners’ motion to recon-
sider). In that motion, petitioners advanced essentially the
same arguments which they had advanced in opposing respondent’s
motion to compel and which we rejected in the October 13, 2000
Order. On October 18, 2000, we denied petitioners’ motion to
reconsider.
On October 23, 2000, this case was called from the calendar
(calendar call) at the Court’s trial session in Indianapolis,
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