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that they had "insufficient information to either admit or deny"
the remaining 9. Among the requests answered "insufficient
information to either admit or deny" were several that concerned
the letters petitioners sent to the Internal Revenue Service on
July 6, 1990, purporting to be their tax returns for the years in
issue. A party must make reasonable inquiry to obtain
information known or readily obtainable that allows the party to
fairly admit or deny. Rule 90(c); Boso v. Commissioner, T.C.
Memo. 1995-228. Petitioners wrote and mailed these letters to
the Internal Revenue Service themselves. We do not believe
petitioners have met the standards set forth in Rule 90 when they
claim "insufficient information to either admit or deny" facts of
which they have personal knowledge.
Respondent's requested admissions relating to documents,
specific facts, and the authenticity of certain documents were a
reasonable attempt to narrow the issues and place facts before
the Court. Petitioners have been given several opportunities to
address the merits of their case and to present evidence in
support of the issues as to which they have the burden of proof.
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Aside
from admitting 24 of the requested admissions, petitioners did
not present in their motion or in their proposed responses any
facts that would tend to refute the deemed admissions. Thus,
petitioners have shown no bona fide dispute as to the specific
factual statements contained in the Request for Admissions, or
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