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respondent was planning to move that the Court impose a section
6673 penalty.
On that same day, respondent served petitioners with a
request for production of documents and a request for
interrogatories. Additionally, respondent served petitioners
with a request for admissions and filed a copy with the Court.
On July 31, 2000, respondent filed a second request for
admissions with the Court, which was also served on petitioners.
Petitioners did not respond to the requests for admissions.
Therefore, each matter to which respondent requested admission is
deemed admitted. See Rule 90(c). Some of those deemed
admissions were:
(1) Petitioners created the Sigerseth Family Trust on August
6, 1992;
(2) In 1995 and 1996, petitioners Charles J. Sigerseth and
Francesca C. Sigerseth were the only two trustees of the
Sigerseth Family Trust;
(3) On page 3 of the declaration of trust of the Sigerseth
Family Trust, it states in the “Trustees' Declaration of Purpose”
that the “Creator” transferred property to the trustees,
including “the exclusive use of His [the creator's] lifetime
services and ALL of His EARNED REMUNERATION ACCRUING THEREFROM,
from any current source whatsoever, so the CHARLES J. SIGERSETH
can maximize His lifetime efforts through the utilization of His
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