- 10 -
from pursuing the same tax deficiency issues in the 1999 tax year
that were decided on the merits for the 1998 tax year.”
By letter dated May 28, 2001, petitioner’s counsel replied
to respondent’s paralegal’s letter of May 18, 2001. In his
letter, petitioner’s counsel stated that he was not familiar with
the “interrelationship” of Mrs. Nguyen to petitioner.
In early June 2001, respondent’s counsel obtained
documentation confirming that petitioner’s son’s medical bills
were paid by Medicaid. At the same time, respondent’s counsel
also obtained the administrative file for petitioner’s 1998
taxable year. Included within that file was the original
“Certificate of Enrollment” from the Fairfax County Public
Schools for petitioner’s son. Upon examining that document,
respondent’s counsel concluded that it had been altered. Also
included within the administrative file for petitioner’s 1998
taxable year was another “Certificate of Enrollment” for
petitioner’s son but with a different enrollment date.
Respondent’s counsel concluded that the second certificate had
also been altered.
Respondent’s counsel continued to develop the facts.3
Ultimately, based on her analysis of the administrative files and
information that she gathered from other sources, respondent’s
3 In her Declaration, respondent’s counsel states that
“During this time I did not receive any information from
petitioner’s counsel that would assist in the resolution of these
issues.”
Page: 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