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(10) Around 1995, the Wards transferred their interest in
the Arctic Building Commercial Partnership to GND;
(11) Around 1995, the Wards transferred their interest in
the Arctic Video City Partnership to GND;
(12) GND paid nothing to acquire the Wards’ interest in the
Arctic Building Commercial Partnership and the Arctic Video City
Partnership;
(13) Around 1995, the Wards transferred their interest in
the office building to WT;
(14) WT paid nothing to acquire the office building;
(15) After the aforementioned transfers, the Wards’
relationship to the transferred partnership interests and
properties did not change;
(16) The Wards, and not the trusts, are the correct
taxpayers to report the income and expenses of the transferred
partnership interests and properties;
(17) Petitioners did not produce documents summonsed by the
revenue agent auditing their 1996 and 1997 returns; and
(18) Although offered an opportunity to do so, petitioners
did not meet with respondent’s counsel for the purpose of
preparing this matter for trial.
Attached to the requests for admissions, among other things,
are: (1) The Wards’ 1995, 1996, and 1997 tax returns; (2) the
notices of deficiency; (3) several letters from the Wards to the
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