Thu Cuc Thi Huynh - Page 8




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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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