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For 1995, petitioners also filed for the automatic 4-month
extension on Form 4868 and submitted a Form 2688 and received an
extended filing date of October 15, 1996. Petitioners’ 1995
return was filed on October 18, 1996.
B. Respondent’s Request for Admissions
On February 24, 2003, respondent served on petitioners’
counsel, Steven Morford (Mr. Morford), a copy of respondent’s
request for admissions (request). The request was filed with the
Court on February 25, 2003. Neither petitioners nor their
counsel responded to the request, and pursuant to Rule 90(c),
each matter set forth in the request was automatically deemed
admitted 30 days after the date of service. See also Morrison v.
Commissioner, 81 T.C. 644, 647 (1983); Freedson v. Commissioner,
65 T.C. 333, 334-36 (1975), affd. on other grounds 565 F.2d 954
(5th Cir. 1978).
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