Sam F. and Ingrid D. Ford - Page 10

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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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