Scott Roman - Page 5

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          your client’s offer be rejected without further consideration.”             
          On February 18, 2003, Mr. Karaszkiewicz hand-delivered documents            
          to Mr. Kroll in response to the January 21, 2003, letter.                   
               In his examination of the hand-delivered documents,                    
          Mr. Kroll found that several of the requested items had not been            
          provided.  He further became privy to new facts indicating that             
          additional collection information statements would be required in           
          order to complete consideration of the offer.  Specifically, the            
          documents revealed that petitioner owned yet another corporation            
          and had recently married, necessitating collection information              
          with respect to the company and to petitioner’s spouse.                     
          Mr. Kroll advised Mr. Karaszkiewicz of these developments by                
          telephone on March 10, 2003, and Mr. Karaszkiewicz said he would            
          try to provide the requested materials by March 25, 2003.                   
               On March 26, 2003, Mr. Karaszkiewicz sent to Mr. Kroll a               
          brief fax stating as follows:  “Mr. Kroll, please excuse the                
          delay in providing the additional documentation which we                    
          discussed.  This delay has been caused exclusively by my trial              
          commitments.  I have not been able to review the documents with             
          Mr. Roman.  I assure you that we will quickly provide them.”                
          When, 6 weeks later, the requested information had not been                 
          submitted, Mr. Kroll determined that the proposed collection                
          alternative could not be accepted and that collection by levy               
          should proceed.  The corresponding Notice of Determination                  

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