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judgment is appropriate where the facts deemed admitted pursuant
to Rule 90(c) support a finding that there is no genuine issue as
to any material fact. Marshall v. Commissioner, 85 T.C. 267
(1985); Morrison v. Commissioner, 81 T.C. 644, 651-652 (1983).
We agree with respondent that the issues pertaining to
petitioners' liability for the deficiencies and additions to tax
in dispute are ripe for summary adjudication. In particular,
petitioner is deemed to have admitted each of the factual
allegations set forth in respondent's request for admissions. We
note that respondent's request for admissions includes a
statement advising petitioners that the allegations set forth
therein would be deemed admitted under Rule 90(c) if not
specifically admitted or denied within 30 days of service of the
request. Based on the record presented, and particularly
petitioners' failure to communicate with the Court or to
otherwise respond to respondent's motion, we conclude that
petitioners have no intention of pursuing this matter further.
The deficiencies determined by respondent in this case arise
from petitioners' failure to report gross receipts, failure to
report a taxable IRA distribution, failure to substantiate
certain cost of goods sold and Schedule C expenses, and from
other adjustments, as set forth in the notice of deficiency. The
factual allegations deemed admitted by petitioners under Rule
90(c) establish that respondent's determinations with respect to
these items are correct. Having examined all of the materials in
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