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the deemed admissions to prepare for trial. Petitioner did not
move before trial for relief from the deemed admissions and
apparently did not notify respondent of his intention to seek
relief from the deemed admissions. Most importantly, petitioner
did not supply respondent with any documents or information in
advance of trial that would have put respondent on notice that
any of the deemed admissions were in error. When petitioner
finally made his oral motion at trial, he offered the Court no
compelling reason why he had failed to respond to the requests
for admission.
Because we find that respondent reasonably relied on the
deemed admissions and that withdrawal of the deemed admissions
would not foster presentation of the merits and would unfairly
prejudice respondent, we shall deny petitioner's motion for
relief from the deemed admissions. See Dahlstrom v.
Commissioner, 85 T.C. 812, 819 (1985); Morrison v. Commissioner,
supra at 649.
B. Income Tax Deficiencies
In general, the Commissioner’s determination of a deficiency
is presumed correct, and the taxpayer bears the burden of proving
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