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On November 21, 2000, petitioner’s counsel sent another
letter to respondent, extending the rescission deadline to
November 28, 2000. Again, petitioner’s counsel did not provide
any of the information or documentation that respondent had
previously requested in respondent’s letters to petitioner.
Rather, petitioner’s counsel asserted that “you may be subject to
attorney fees and costs by not timely responding to this letter.”
On December 6, 2000, petitioner commenced the present case
by filing a petition for redetermination. See sec. 6213(a).
Petitioner placed the entire amount of the deficiency in dispute,
assigning error to each of the adjustments made by respondent in
the notice of deficiency. Petitioner attached to her petition a
number of documents, all but one of which (monthly telephone
statements) were already in respondent’s possession.
On March 6, 2001, respondent filed an answer. In the
answer, respondent denied all of petitioner’s assignments of
error.
On April 9, 2001, respondent’s paralegal spoke with the
manager of the apartment complex where petitioner resided. This
conversation was followed by a written request for documentation.
The written request stated, in part, as follows:
This is to follow up our telephone conversation of
April 9, 2001, and to request that you forward copies
of the documents you mentioned pertaining to the rental
of Apt. #207 * * * . As I recall, you indicated that
you have a copy of the lease agreement in effect for
1999 for Apt. 207, and the application papers Ms. Tra
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