Wayne E. and Dorothy E. Wells - Page 14

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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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