James Luther Cochrane - Page 5

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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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