Casey A. Roginiel - Page 4




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               On or about December 20, 2000, respondent received                     
          additional documentation from petitioner.  The documentation                
          included:  (1) a letter from the school attended by petitioner’s            
          children; (2) Social Security cards for the children; (3)                   
          magazine covers addressed to the children at petitioner’s home              
          address; and (4) a customer statement to petitioner for child               
          care for the children.  The school letter did not list the                  
          children’s home address.                                                    
               On or about January 23, 2001, petitioner met with his                  
          counsel.                                                                    
               On January 26, 2001, respondent sent a second Form 886-A to            
          petitioner requesting additional information to substantiate                
          petitioner’s positions.  Again, respondent enclosed a Form 886-H            
          detailing acceptable documentation.                                         
               On February 20, 2001, petitioner’s petition was filed.  On             
          April 24, 2001, respondent’s answer was filed.                              
               After the petition was filed, Appeals Officer Loren L.                 
          Peterson (Mr. Peterson) was assigned petitioner’s case.  On or              
          about May 24, 2001, Mr. Peterson mailed a letter to petitioner to           
          schedule a conference to attempt to settle the case without going           
          to trial.                                                                   
               During July 2001, respondent and petitioner’s counsel had              
          two telephone conferences with regard to petitioner’s case.  As a           
          result of the telephone negotiations and the submissions of the             






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