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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.”
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Last modified: May 25, 2011