- 7 - could not identify any document showing a nontaxable source because they were not in possession of their records. The interrogatories asked petitioners to: Provide the name, current address, current telephone number, and occupation of all persons who have any personal knowledge as to the non-taxable sources of deposits into petitioner husband’s Union National Bank account * * * [Nationwide account] for the year 1996 and referred to above. Also provide a description of their anticipated testimony and indicate the persons’ relationship to petitioners. Respondent used similar language to inquire about the Cohen account and the NHIL account. Petitioners responded that they were “not aware of anyone at present having any knowledge of information mentioned in Respondent’s interrogatory”. Petitioners used similar language in response to interrogatories referring to the Cohen account and the NHIL account. Respondent requested that petitioners produce documents relating to deposits made into each of their accounts. Specifically, respondent requested that petitioners “provide all work papers, deposit slips, bank statements, and any other documents showing the correct non-taxable transfers and the nature of those non-taxable items” for the Nationwide account, the Cohen account, the BMC account, and the NHIL account. On July 12, 2001, petitioners responded to the request for production of documents by stating “petitioners do not presently have any record mentioned herein.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011