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required within 45 days after service of those interrogatories
and that his continuing failure to cooperate would result in the
filing by respondent of a motion to compel answers to those
interrogatories. Respondent further advised petitioner in that
letter about the Court's Standing Pretrial Order (Order) that
mandated, among other things, that the parties stipulate all
relevant matters not privileged and that cautioned the parties
that any unexcused failure to comply with the Order might result
in appropriate sanctions, including dismissal. The February 29,
1996 letter invited petitioner, once again, to meet with respon-
dent as soon as possible to begin preparation of a stipulation of
facts. That letter cautioned petitioner that, because of his
continued failure to contact respondent and to cooperate in
preparing the case, respondent was prepared to file a motion to
dismiss the petition for lack of prosecution. Petitioner failed
to respond to respondent's February 29, 1996 letter.
On March 14, 1996, respondent filed a request for admissions
with the Court. On March 13, 1996, respondent served petitioner
by mail with a copy of that request. Petitioner did not file any
response to that request for admissions. Consequently, each
matter set forth therein, including the following, is deemed
admitted. Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272
(1985); Morrison v. Commissioner, 81 T.C. 644, 647 (1983).
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