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collection of his 1997, 1998, 1999, 2000, 2001, and 2002 income
tax liabilities.
Confronted with petitioner’s refusal to work toward a
stipulation of facts, on March 7, 2007, respondent filed a motion
to show cause why proposed facts in 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 March 9, 2007, the Court issued an order to show cause
under Rule 91(f), requiring petitioner to file a response on or
before March 29, 2007, as to why matters set forth in
respondent’s motion should not be deemed admitted. Additionally,
the Court ordered that if petitioner’s response was evasive or
not fairly directed to the proposed stipulation or portion
thereof, that matter or portion thereof would be deemed
stipulated for purposes of the pending case, and an order would
be entered accordingly, pursuant to Rule 91(f).
On April 2, 2007, petitioner filed a response to the Court’s
order to show cause.
On April 4, 2007, the Court made absolute its order to show
cause under Rule 91(f), and ordered that the facts and evidence
set forth in respondent’s proposed stipulation of facts were
deemed established.
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Last modified: November 10, 2007