OPINION
HALL, Judge:
These proceedings arise on this Court's order dated April 7, 1978, directing petitioners to file a response with the Court showing why the matters set forth in respondent's proposed additional supplemental stipulation of facts should not be deemed admitted for purposes of these cases, and on respondent's motion filed April 10, 1978, to impose sanctions under Rule 104 (Tax Court Rules of Practice and Procedure) and requesting partial...
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