- 5 - 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.Page: Previous 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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