Patricia R. Carpentier - Page 5




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               ad. You failed to file an income tax return for the                    
               taxable year 1990.                                                     
               ae. You failed to file an income tax return for the                    
               taxable year 1991.                                                     
               af. You failed to file an income tax return for the                    
               taxable year 1992.                                                     
               ag. You failed to file an income tax return for the                    
               taxable year 1993.                                                     
               ah. Your failure to file an income tax return for the                  
               taxable year 1989 was not due to reasonable cause.                     
               ai. Your failure to file an income tax return for the                  
               taxable year 1990 was not due to reasonable cause.                     
               aj. Your failure to file an income tax return for the                  
               taxable year 1991 was not due to reasonable cause.                     
               ak. Your failure to file an income tax return for the                  
               taxable year 1992 was not due to reasonable cause.                     
               al. Your failure to file an income tax return for the                  
               taxable year 1993 was not due to reasonable cause.                     
               am. You failed to pay estimated tax for the taxable                    
               year 1989.                                                             
               an. You failed to pay estimated tax for the taxable                    
               year 1990.                                                             
               ao. You failed to pay estimated tax for the taxable                    
               year 1991.                                                             
               ap. You failed to pay estimated tax for the taxable                    
               year 1992.                                                             
               aq. You failed to pay estimated tax for the taxable                    
               year 1993.                                                             
               Paragraphs a., b., c., and d. of respondent's Second Request           
          for Admissions, as quoted above, represent concessions by                   
          respondent that, contrary to respondent's determinations in the             






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