107 T.C. No. 2 UNITED STATES TAX COURT JAMES LUTHER COCHRANE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2002-95. Filed August 7, 1996. P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case. Rule 90(c), Tax Court Rules of Practice and Procedure, generally requires that a party upon whom a request for admission is served specifically admit or deny the proposed admission. Rule 104(c), Tax Court Rules of Practice and Procedure, provides that the Court may sanction a party who fails to obey an order with respect to the provisions of Rule 90 by ordering that the matter in the requested admissions be taken as established for purposes of the case. Rule 104(d) provides that an evasive or incomplete response to a requested admission is to be treated as a failure to respond.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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