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'United States' in order to specify any of several possible
definitions applicable to these terms."
(4) In request 6, respondent asserted that petitioner did
not receive any income from sources outside the United States
during the years in issue. In response, petitioner stated that
"respondent does not cite statute and its implementing regulation
defining the terms 'income' or 'United States' used in the
allegation."
(5) In request 10, respondent asserted that petitioner
reported on his tax returns for 1983 through 1985 that certain
wages were excluded from gross income as income earned while
physically present in a foreign country during the entire 12
months of the taxable year. In response, petitioner contended
that the "Statements are presumptive of law and are not facts
susceptible to admission or denial by petitioner." In addition,
petitioner stated that "respondent does not define the term
'wages' or the term 'taxable years' used in reference to
petitioner in this case" and that "respondent fails to identify
any * * * authority for establishing California [as a] state
under federal revenue jurisdiction."
(6) In requests 15 through 17, respondent asserted that
during 1984 through 1986, petitioner conducted a tax return
preparation and tax counseling business and that petitioner
received, but failed to report, fees in 1984, 1985, and 1986.
Respondent listed the names of specific payors and the amounts
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