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and comply with the Court's policies and requirements regarding
pretrial preparation. Petitioners did not respond to this
letter.
On June 5, 1998, respondent served petitioners with requests
for admission pursuant to Rule 90. The requested admissions were
as follows:
1. For the 1991 and 1993 taxable years
petitioners are not entitled to dependency exemptions
in the amounts of $10,750.00 and $9,400.00,
respectively.
2. For the 1991 and 1993 taxable years
petitioners are not entitled [to] * * * deductions for
Schedule C expenses in the amounts of $86,560.00 and
$21,140.00, respectively.
3. In 1991 petitioners received a taxable
distribution from an I.R.A. in the amount of $1,121.00.
Petitioners failed to report this item on their 1991
return.
4. For the 1991 and 1993 taxable years
petitioners are not entitled to deductions for rental
expenses in the amounts of $36,944.00 and $30,440.00,
respectively.
5. For the 1991 and 1993 taxable years
petitioners are not entitled to itemized deductions in
the amounts of $28,594.00 and $35,925.00, respectively.
6. For the 1991 taxable [year], petitioners are
not entitled to an additional deduction for exemptions
in the amount of $2,064.00.
7. The petitioners are liable for the failure to
timely file penalty, pursuant to Internal Revenue Code
("I.R.C.") section 6651(a)(1) for the 1991 taxable
year.
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