- 8 - 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. TraPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011