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clearly advised petitioners they had 30 days to respond by filing
a written answer with the Court and serving respondent with a
copy of the written answer. Attached to the request were:
Copies of the notices of deficiency for both petitioners; copies
of letters dated July 6, 1990, with incomplete Forms 1040
attached, that petitioners had sent to the Internal Revenue
Service, purporting to be petitioners' tax returns for the years
in issue; and Bureau of Labor Statistics data used for computing
gross income after the base year of 1981.
After respondent's Request for Admissions had been sent to
petitioners, petitioners sent respondent a letter on March 11,
1994, requesting informal discovery "as provided by the Rules of
the United States Tax Court." This letter requested all
documents that "prove the gross income for Wayne Wells for the
tax years 1986, 1987, 1988 and 1989", "prove the gross income for
Dorothy Wells for the tax years 1986, 1987, 1988 and 1989", and
"prove the purported civil fraud penalties asserted against
Dorothy Wells." Respondent's reply to this letter reminded
petitioners they had received documents, attached to the proposed
stipulation of facts, which supported the deficiencies and the
additions to tax. Respondent also enclosed four other relevant
documents with this letter.
The 30-day period following service of respondent's Request
for Admissions expired on April 7, 1994. Petitioners neither
answered nor objected to the request during the 30-day period.
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