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In interpreting and applying our Rules, we generally seek
guidance from judicial decisions interpreting the counterparts to
our Rules in the Federal Rules of Civil Procedure. Dusha v.
Commissioner, 82 T.C. 592, 599 (1984). The analog to Rule 90(a)-
(c) is rule 36(a) of the Federal Rules of Civil Procedure.
Freedson v. Commissioner, 65 T.C. 333, 334 (1975), affd. 565 F.2d
954 (5th Cir. 1978); Notes to Rule 90(a)-(c), 60 T.C. 1057, 1114-
1116.
In Asea, Inc. v. Southern Pac. Transp. Co., 669 F.2d 1242,
1245 (9th Cir. 1981), the court upheld the propriety of imposing
the sanction of deeming certain matters admitted for violation of
rule 36(a) of the Federal Rules of Civil Procedure. In doing so,
the court stated, id. at 1246, that the discovery process is
subject to the "overriding limitation" of good faith, that
"callous disregard" of discovery responsibilities cannot be
condoned, and that:
The general power of the district court to control the
discovery process allows for the severe sanction of
ordering a matter admitted when it has been
demonstrated that a party has intentionally disregarded
the obligations imposed by Rule 36(a). [Id. at 1247.]
The court expressly stated:
It is also clear that an evasive denial, one that does
not "specifically deny the matter," or a response that
does not set forth "in detail" the reasons why the
answering party cannot truthfully admit or deny the
matter, may be deemed an admission. * * * Since such
a response does not comply with the literal
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