Bradley M. Cohen and Kathy A. Cohen - Page 7




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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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