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C. Respondent's Request for Admissions and Petitioner's
Responses
On June 5, 1997, respondent served a request for admissions
on petitioner under Rule 90. Respondent's request for admissions
and petitioner's responses are as follows:
1. Petitioner admits that he did not file a U.S.
Individual Income Tax Return, Form 1040, for 1989, 1990, 1991 and
1992.
2. Petitioner admits that from 1989 to 1992 he received:
(a) Compensation for services as an airline pilot for American
Airlines in the amounts of $149,663, $150,708, $176,719, and
$155,171; (b) interest income from the American Airlines Credit
Union in the amounts of $521, $147, $409, and $587; and (c)
dividend income from various Merrill Lynch accounts in the
amounts of $853, $905, $1,075, and $457. Petitioner denies that
this income is taxable. Petitioner's response also includes the
word "jurisdiction" without explanation. We assume this (and
other unexplained references to "jurisdiction" in petitioner's
response to respondent's request for admissions) relates to
petitioner's contention in his petition that the Commissioner
lacked jurisdiction to issue the notices of deficiency.
3. Petitioner admits that he received: (a) Capital gain
income from various Merrill Lynch accounts totaling $4,754 in
1989; and (b) income of $88 from the sale of stock from
Merrill Lynch in 1990, and $2,786 in 1991. Petitioner denies
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