- 3 -
pursuant to Rule 90(c).3 Alexander v. Commissioner, 926 F.2d
197, 198-199 (2d Cir. 1991), affg. T.C. Memo. 1990-315; Marshall
v. Commissioner, 85 T.C. 267, 272 (1985); Morrison v.
Commissioner, 81 T.C. 644, 647 (1983).
The following is a summary of the matters that petitioner is
deemed to have admitted pursuant to Rule 90(c).
Petitioner was pastor of the Cornerstone Baptist Church in
Union City, Indiana, during the taxable years 1988 through 1993.
Petitioner did not file income tax returns for the taxable years
1988 through 1993. Petitioner had taxable income in the amounts
3 Rule 90 states in pertinent part:
(a) Scope and Time of Request: A party may serve
upon any other party a written request for the
admission, for purposes of the pending action only, of
the truth of any matters which are not privileged and
are relevant to the subject matter involved in the
pending action, but only if such matters are set forth
in the request and relate to statements or opinions of
fact or of the application of law to fact, including
the genuineness of any documents described in the
request. * * *
* * * * * * *
(c) Response to Request: Each matter is deemed
admitted unless, within 30 days after service of the
request or within such shorter or longer time as the
Court may allow, the party to whom the request is
directed serves upon the requesting party (1) a written
answer specifically admitting or denying the matter
involved in whole or in part, or asserting that it
cannot be truthfully admitted or denied and setting
forth in detail the reasons why this is so, or (2) an
objection, stating in detail the reasons therefor.
* * *
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