Stephen V. Talmage - Page 6

          motion were copies of respondent's July 20 and July 26, 1995,               
          letters, in which respondent had attempted to schedule meetings             
          with petitioner to prepare the case for trial and which had been            
          accompanied by a proposed stipulation of facts, an informal                 
          request for information, a copy of Rule 91 of the Court's Rules             
          (concerning stipulations for trial), a copy of Publication 947,             
          and two copies of Form 2848.  Petitioner  returned these letters            
          to respondent stamped as follows:                                           
                                  REFUSED FOR CAUSE                                   
                                  WITHOUT DISHONOR                                    
                                    U.C.C. 3-501                                      
               Also on October 13, 1995, we issued another order in which             
          we noted that petitioner's objection and request for admissions             
          had continued the tax protester course that we had warned him               
          against.  We rejected petitioner's tax protester arguments and              
          referred him to the recently issued opinion in Santangelo v.                
          Commissioner, T.C. Memo. 1995-468, which had rejected the                   
          identical section 83 argument made by the taxpayer in that case.            
          We made absolute our order to show cause and thereby accepted as            
          established for the purposes of this case the facts set forth in            
          respondent's proposed stipulation of facts.  We once more urged             
          petitioner to provide respondent's counsel with the documentation           
          supporting his asserted business expenses and itemized deductions           
          and to settle the case by agreement.                                        
               Our order of October 13, 1995, also instructed the Clerk of            
          the Court to return petitioner's request for admissions unfiled             

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