Janet Kline - Page 4

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                        (j) A decision was entered on January 17, 1991,                                   
                  and became final on April 16, 1991.                                                     
                        (k) A notice of deficiency was mailed to                                          
                  petitioner with respect to the additions to the tax                                     
                  affected items on April 3, 1992, which date was prior                                   
                  to the expiration of the one-year period for assessment                                 
                  and collection under I.R.C. 6229(f).                                                    
                  On September 4, 1992, respondent served a copy of her answer                            
            upon Attorney Driscoll.  On November 5, 1992, respondent filed a                              
            motion for entry of an order that the undenied allegations in her                             
            answer be deemed admitted in accordance with Rule 37(c).                                      
            Attorney Driscoll was served with a copy of the motion.  Also on                              
            November 5, 1992, Attorney Driscoll was served with a notice from                             
            the Clerk of the Court that respondent had filed a motion for                                 
            entry of an order.  The notice indicated that                                                 
                        If petitioner files a reply as required by Rule                                   
                  37(a) and (b) of this Court's Rules on or before                                        
                  November 27, 1992, respondent's motion will be denied.                                  
                  If petitioner does not file a reply as directed herein,                                 
                  the Court will grant respondent's motion and deem                                       
                  admitted for purposes of this case the affirmative                                      
                  allegations in the answer.                                                              

            No reply was filed by petitioner, and, accordingly, respondent's                              
            motion was granted on December 7, 1992.                                                       
                  This case was originally set for trial on October 12, 1993.                             
            Respondent filed a motion for continuance which was granted by                                
            the Court on August 19, 1993.  The case was then set for trial on                             
            October 11, 1994.  Respondent filed a motion for continuance                                  
            which was granted by the Court on August 22, 1994.  The two                                   
            motions to continue referred to related cases under submission                                




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