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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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