Patricia R. Carpentier - Page 2

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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           
               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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