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On March 26, 2001, respondent filed a request for
admissions, containing 22 admissions, setting forth the same
amounts and characterizations of gross income determined in the
notices of deficiency sent to petitioners. Petitioners filed the
following answer to respondent’s request for admissions:
In response to your request for admission dated March
20, 2001 we wish to state: We had a major change of
office personnel in June 2000. Much of the information
you have requested has been either lost or misplaced.
We will have to assume that the items #1-22 are correct
as listed in your request.
In their amended petition, petitioners contend that on March
27, 1987, respondent’s agents conducted a seizure at Interstate
Energy Enterprises, Inc.’s (IEEI) manufacturing facility which
was “wrongful, illegal and unconstitutional” and caused the loss
of petitioners’ property and business. Petitioners’ position in
their amended petition is that the damages caused by the seizure
activities should be taken into consideration when calculating
their personal income taxes for the years since 1987.2 The
amount of the loss that petitioners claim they are entitled to is
based on the value of Mr. Tonn’s labor.
Over a period of years prior to 1981, Mr. Tonn developed an
2On July 26, 2000, this Court entered an order dismissing
for lack of jurisdiction all years subsequent to 1987 with the
exception of petitioners’ taxable years 1996 and 1997 and Mr.
Tonn’s taxable year 1995.
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Last modified: May 25, 2011