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inconsistent positions and asserted tax on the corrected income
of the trusts.
On October 12, 2000, petitioners invoked the jurisdiction of
this Court by timely filing petitions. At the time they filed
the petitions, the Wards resided in Anchorage, Alaska, and the
trusts’ mailing addresses were in Anchorage, Alaska. In the
answers, respondent denied petitioners’ assignments of error.
By notice dated January 18, 2001, the Court set these cases
for trial at the Court’s Anchorage, Alaska, session beginning
June 18, 2001. This notice specifically stated: “YOUR FAILURE
TO APPEAR MAY RESULT IN DISMISSAL OF THE CASE AND ENTRY OF
DECISION AGAINST YOU.” Although our standing pretrial order
required petitioners to submit trial memoranda, they never did
so.
On April 2, 2001, respondent filed a motion to consolidate
for trial, briefing, and opinion the Wards’ case with the cases
of the trusts. On April 12, 2001, the Court granted this motion.
On April 9, 2001, respondent filed respondent’s first
request for admissions in each of the cases. Petitioners did not
respond to the requests for admissions. Therefore, each matter
of which respondent requested admission is deemed admitted. Rule
90(c). Some of these deemed admissions were:
(1) The returns attached to the requests for admissions are
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