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On May 6, 1996, respondent filed a motion to review the
sufficiency of petitioner's objections to respondent's requests
for admission. On May 9, 1996, this Court ordered petitioner to
respond to the requested admissions on or before May 20, 1996.
The order expressly warned petitioner that if he failed to
comply, the Court would be inclined to impose sanctions pursuant
to Rule 104(c), the provisions of which were quoted in the order.
On May 28, 1996, we granted petitioner's request for an extension
of time to June 10, 1996, in which to file his response.
On June 10, 1996, petitioner served respondent with
petitioner's supplemental response to the requests for admission.
In responses 31 through 33, petitioner admitted that the 1983,
1984, and 1985 Federal income tax returns attached as exhibits to
respondent's requests for admission "represent return information
filed by petitioner for 1983, 1984, and 1985". However,
petitioner qualified these admissions and noted an objection to
these exhibits "if they constitute improper forms to utilize for
his correct filing status during these periods."2
2Each of petitioner's 1983, 1984, and 1985 returns reports
wages and includes a Form W-2 from his employer, General Dynamics
Corp. The 1983 return also includes a Form W-2 from petitioner's
employer, Rohr Industries, Inc. On each of those returns,
petitioner claimed that all his wage income was excludable from
taxable income as income earned for services performed in a
foreign country. On Forms 2555, attached to each return,
petitioner stated that he was physically present in a foreign
country for the entire 12-month period covered by each return.
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