James E. Stafford - Page 5

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          response to the Court's request that he provide specific evidence           
          regarding the matters raised by respondent, petitioner refused,             
               I stand on the documentation that I have provided this Court           
               that there are no implementing Federal regulations in title            
               26 for enforcement actions against me.  I stand on that.               
               That is all I have to say to this Court.                               
          Respondent then filed the instant motion for summary judgment               
          pursuant to Rule 121.                                                       
               This case was recalled 2 days later.  Petitioner's oral                
          motion to dismiss was denied.  Petitioner's original and                    
          supplemental responses to the show cause order were determined to           
          be unresponsive and, thus, not in compliance with that order and            
          Rule 91.  Consequently, respondent's proposed stipulations of               
          fact were accepted as established for purposes of this case.                
          Rule 91(f); Marcus v. Commissioner, 70 T.C. 562, 573 (1978),                
          affd. without published opinion 621 F.2d 439 (5th Cir. 1980).               
          Additionally, petitioner's original and supplemental responses to           
          respondent's requests for admission were determined to offer                
          neither sufficient answers nor justified objections to any                  
          matters contained in the requested admissions.  Consequently, the           
          requested admissions were deemed admitted for purposes of this              
          case.  Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272               
          (1985).  The Court then inquired of petitioner whether he had any           
          other evidence to submit or factual matters to dispute.                     
          Petitioner responded in the negative.  Consequently, the Court              
          vacated the scheduled trial and granted petitioner 30 days to               

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