K & M La Botica Pharmacy, Inc. et al. - Page 8




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          witness merely for the purpose of probing veracity and                      
          credibility.  As this Court previously stated with disapproval in           
          another proceeding involving Rule 75:  “It does not appear that             
          any purpose would be served by deposing Nick except to get Nick’s           
          testimony before the trial.”  DeLucia v. Commissioner, 87 T.C.              
          804, 813 (1986).                                                            
               Hence, we conclude that before the Court will order a                  
          deposition pursuant to Rule 75, the requesting party must allege            
          with a greater degree of specificity than has been shown in this            
          proceeding the nature of the information sought and the grounds             
          for the party’s belief that such will be forthcoming from a                 
          particular deponent.  Here, the first of petitioners’ reasons for           
          deposing Mr. Darwish, to test the extent of his knowledge and his           
          veracity, amounts to little more than a request to cross-examine            
          Mr. Darwish before trial.  The second reason, to determine                  
          whether Mr. Darwish is aware of any further information or                  
          witnesses which can shed light on his allegations, merely seeks             
          to interrogate Mr. Darwish generally in the imperfectly formed              
          hope that something might turn up.                                          
               In addition, from a practical standpoint, we note that there           
          exists even less justification for such unarticulated probing in            
          the unique circumstances of this case than might be present in              
          other scenarios.  Petitioners have already had the opportunity to           
          review the substance of Mr. Darwish’s allegations in three forms,           






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