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worked on the spreadsheets every night for 2 weeks, then
submitted them to Watson.
Petitioner telephoned Watson on June 20, 2001, and told her
that he had found canceled checks for the telecommunication
expenses. Watson then agreed to withhold a decision on whether
the filing of a lien was proper until respondent’s examination
division reviewed petitioners’ telecommunication expense
deductions for the years in issue. Watson incorrectly told
petitioner on June 26, 2001, that petitioners’ file would be sent
to the examination division in Melbourne, Florida. Instead, it
was sent to PSP, an internal address of respondent not further
identified in the record.
On November 5, 2001, petitioner asked Watson to expedite
consideration of petitioners’ case because the lien was hurting
his credit. Petitioner told Watson that he could not obtain a
car loan while their case was pending. Watson told petitioner
that petitioners’ file was supposed to be in Melbourne and that
she had been unable to find it. Petitioner brought records to
Watson on November 7, 2001, but personnel in respondent’s
Melbourne examination division could not work on petitioners’
case because they did not have petitioners’ file. Watson began
looking for petitioners’ file on November 7, 2001. Watson
learned that Arthur Washburn (Washburn), an employee of
respondent in PSP, had signed a transmittal document for
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Last modified: May 25, 2011