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the introduction of petitioners' 1982 Federal income tax return
which reported petitioners' amount of tax as zero.
Alternatively, if respondent were to have the burden of
proof, she could satisfy her burden of proof based on deemed
admissions. See, e.g., Doncaster v. Commissioner, 77 T.C. 334
(1981); Baldwin v. Commissioner, T.C. Memo. 1984-119. Pursuant
to Rule 90(c), each matter is deemed admitted unless within 30
days after service of the request the party to whom the request
is directed serves upon the requesting party either (1) a written
answer specifically admitting or denying the matter involved or
(2) an objection. Respondent issued requests for admissions on
February 8, 1995. Petitioner never responded to respondent's
requests for admissions. Thus, even if respondent had the burden
of proof, she would have satisfied her burden of proof with
respect to the increased deficiency, since respondent's requests
are deemed admitted pursuant to Rule 90(c), including an admis-
sion that the deficiency for the taxable year 1982 is in the
amount of $29,913.
Lack of Prosecution
With respect to respondent's Motion to Dismiss for Lack of
Prosecution as to petitioner Diana C. Raquet, Rules 123(b) and
149(a) provide as follows:
[Rule 123](b) Dismissal: For failure of a
petitioner properly to prosecute or to comply with
these Rules or any order of the Court or for other
cause which the Court deems sufficient, the Court may
dismiss a case at any time and enter a decision against
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