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petitioners interrogatories including Interrogatory No. 1, which
reads as follows:
When Sam Ford pled guilty to filing a false
federal income tax return for the taxable year 1986, he
admitted that he failed to report more than $2.8
million dollars of income from the sale of securities
during 1986. How did Sam Ford arrive at that amount of
unreported income, and how was it computed? Please
provide a breakdown of the shares he sold by date, by
company, and by amount realized.
Petitioners responded to Interrogatory No. 1 as follows:
Petitioner Sam Ford did not "arrive at" the amount
of $2.8 million that was the subject of the plea in
question. Rather, the federal Government "arrived at"
said amount after examining the return of Marc J. Ford.
The breakdown of shares sold by date, by company and
the amount realized, that are relative to said amount,
should be set forth on the 1986 return of Marc J. Ford.
Petitioners also served interrogatories upon respondent,
including Interrogatory No. 40. Subsequently, a revised version
of Interrogatory No. 40 was served upon respondent. Revised
Interrogatory No. 40 reads as follows:
What evidence does the respondent have that the $2.8
million reported on Marc Ford's return and the subject
of the allocution was realized on the shares giving
rise to the adjustment discussed in exhibit A to the
statutory notice, such evidence to include specific
identification of shares disposed of including dates of
disposition, amounts realized and basis.
On May 8, 2002, respondent issued an eight-page response to
petitioners' revised Interrogatory No. 40 as follows:
The respondent does not have direct evidence that
the Tillex and the Beverly Development stock, which
gave rise to the capital gains adjustment in the notice
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