ABFA Trust - Page 2




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          filed with the Court by a proper party as required by Rule                  
          60(a).2  The petition was filed with the Court in the name of               
          petitioner by Mr. Jablonski, in his stated capacity as                      
          petitioner’s trustee.  Petitioner petitioned the Court to                   
          redetermine respondent’s determination of deficiencies of                   
          $323,810 and $245,822 in its Federal income tax for 1995 and                
          1996, respectively, accuracy-related penalties under section                
          6662(a) of $64,762 and $49,164.40, respectively, and a $64,762              
          addition to tax for 1995 under section 6651(a).                             
               On June 27, 2000, we ordered petitioner to respond to                  
          respondent’s motion by July 11, 2000, setting forth in its                  
          response its position as to the motion and attaching any                    
          pertinent documents in support of its position.  We ordered                 
          petitioner to list in its response the name of its trustee and a            
          list of its assets and liabilities as of the date of the                    
          response.  We ordered petitioner to attach to its response a copy           
          of the trust instrument(s) under which it has operated on or                
          after the date of the petition.  We admonished petitioner that we           
          might dismiss its case if it did not comply fully with our order.           
               On July 17, 2000, petitioner filed its response with the               
          Court.  The response attached a copy of a trust instrument for              


          2 Rule references are to the Tax Court Rules of Practice and                
          Procedure.  Section references are to the Internal Revenue Code             
          in effect for the years in issue.                                           





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