Patricia Williams, a.k.a. Patricia Richardson, a.k.a. Tish Martinson - Page 8

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          files contained no canceled checks, bank statements, or bank                 
          deposit slips.                                                               
               A "Branerton letter", dated November 26, 1996, from District            
          Counsel Udrys was sent to Mr. Guterman informing him that                    
          respondent was preparing for trial.  The letter specifically                 
          requested any documentation in Mr. Guterman's possession that would          
          demonstrate the nontaxable sources of petitioner's bank deposits.            
          Mr. Guterman requested (and received) additional time to prepare             
          answers to the Branerton letter questions and complete his own bank          
          deposits analysis.  By letter dated February 24, 1997, District              
          Counsel Edwin Herrera again asked for Mr. Guterman's responses and           
          bank deposit analysis.  On March 13, 1997, Mr. Guterman forwarded            
          his Branerton letter responses and bank deposit analysis to                  
          district counsel's office.                                                   
               On April 30, 1997, following several telephone conferences              
          between respondent and Mr. Guterman, Appeals Officer Millang                 
          formally offered a settlement proposal which subsequently led to             
          the stipulation of settled issues.                                           
               Petitioner then sought reasonable litigation and                        
          administrative costs from respondent, which respondent rejected.             
          On June 20, 1997, petitioner filed the instant motion for award of           
          litigation and administrative costs.                                         
          Discussion                                                                   







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