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married filing separately, to a personal exemption, and to the
self-employment tax deduction.
On September 19, 1995, we issued an order directing
petitioner to file a response showing why the facts and evidence
set forth in respondent's proposed stipulation of facts should
not be accepted as established for the purposes of the case.
On October 3, 1995, petitioner sent respondent Petitioner's
Request for Admissions, which demanded answers to 21 questions of
a general legal nature without any reference to the particular
circumstances of this case.
Petitioner's Objection To Motion To Show Cause Why Proposed
Facts In Evidence Should Not Be Accepted As Established was filed
on October 12, 1995. It contained a potted history of early
income tax cases, culminating with some references to
petitioner's efforts to file a return under section 83 that would
obviate any taxable gain from his services, all of which
purportedly led petitioner to conclude that his receipts were not
income and that this Court had no jurisdiction over the case. It
also contained various complaints about the procedures that
respondent had followed in this case.
On October 13, 1995, this Court filed respondent's Motion
For Protective Order, which asked this Court to enter an order
that respondent need not answer petitioner's request for
admissions because it had been made shortly before trial, without
the informal consultation required by Branerton Corp. v.
Commissioner, 61 T.C. 691 (1974). Attached to respondent's
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