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respondent partial summary judgment with respect to all matters
deemed admitted as a consequence of petitioner's failure to
respond to respondent's Second Request for Admissions and
petitioner's failure to file a reply to respondent's Amendment to
Answer.
Background
On November 6, 1995, respondent issued notices of deficiency
to Patricia R. Carpentier (petitioner) determining deficiencies
in and additions to her Federal income taxes for 1989, 1990,
1991, 1992, and 1993. Respondent determined that petitioner
failed to file tax returns for the years in issue, failed to
report various items of income (including interest, dividends,
rents, capital gains, and a tax refund), and failed to pay
estimated taxes. Petitioner filed a timely petition for
redetermination with the Court.
On October 22, 1996, Kevin O'Hara filed an entry of
appearance on behalf of petitioner. On March 4, 1997, Mr. O'Hara
filed a motion to withdraw from the case, citing petitioner's
interference in his efforts to settle the case. The Court
granted Mr. O'Hara's motion to withdraw.
On April 3, 1997, Timothy P. Peabody filed an entry of
appearance on behalf of petitioner.
On August 31, 1999, respondent filed a Second Request for
Admissions requesting that petitioner admit the following:
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