Lois Lipton - Page 5

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          the forms necessary to request Individual Taxpayer Identification           
          Numbers (ITINs) for his children.                                           
               Shortly after the visit to the IRS office, Mr.                         
          Khalil Aly submitted tax forms to Delcare’s payroll department.             
          These forms indicated that he wished to claim exemptions for six            
          children.                                                                   
               Mr. Khalil Aly submitted ITIN requests for his six children            
          in the late spring of 2001.  Mr. Khalil Aly received at least two           
          replies to these requests.  The first response occurred                     
          approximately 1 month after his initial submissions and contained           
          a set of supplemental questions pertaining to his                           
          children’s residency.  Mr. Khalil Aly replied to this request.  A           
          second reply followed shortly thereafter, again requesting                  
          additional information with respect to the children’s residency.            
          Correspondence of this nature continued for 12 months following             
          Mr. Khalil Aly’s initial request.                                           
               Petitioner thereafter enlisted the assistance of her local             
          Congressman to procure the ITINs for Mr. Khalil Aly’s children.             
          The Congressman’s staff, in turn, enlisted the assistance of the            
          Commissioner’s Taxpayer Advocate Service, which informed Mr.                
          Khalil Aly in May 2002, that ITINs could not be issued for his              
          children because as of that date, he had not provided                       
          documentation showing that his children satisfied the residency             
          requirement.  Thereafter, Mr. Khalil Aly neither provided the IRS           






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