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and 2000, and (3) petitioner is liable for additional self-
employment tax in 1999 and 2000.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Confronted with petitioner’s refusal to work toward a
stipulation of facts, on September 3, 2004, respondent filed a
motion to show cause why proposed facts and evidence should not
be accepted as established pursuant to Rule 91(f). Respondent
attached to his motion a proposed stipulation of facts and
exhibits. On September 7, 2004, the Court issued an order to
show cause under Rule 91(f), requiring petitioner to file a
response on or before September 27, 2004, as to why matters set
forth in respondent’s motion should not be deemed admitted. On
October 12, 2004, petitioner filed a response to the Court’s
order to show cause. On October 20, 2004, the Court made
absolute its order to show cause under Rule 91(f), finding that
petitioner’s response was evasive and not fairly directed to
respondent’s proposed stipulation of facts and ordering that the
facts and evidence set forth in respondent’s proposed stipulation
of facts were deemed established, and the exhibits in the
proposed stipulation of facts were received into evidence and
made a part of the record of the cases. More than 2 months after
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