Katherine Ilovar Rodriguez - Page 8

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               Petitioner then stated that she wanted to “settle” the case            
          immediately.  When asked by the Court what she meant by using the           
          word “settle”, she explained that she wanted to pay the subject             
          amounts in full.  She said she wanted to “concede” the case.  She           
          testified that she had offered several times to fully pay the               
          outstanding amounts.  According to petitioner, she made an offer            
          to Ms. Dellosso to fully pay the taxes for 1993, 1994, and 1995             
          but was rebuffed.  Petitioner stressed that her offer to pay in             
          full was limited to the tax years before the Court.                         
               Petitioner, while insisting that she wanted to “concede” her           
          case, nevertheless wanted her husband to testify, which testimony           
          the Court allowed.  Petitioner’s husband testified that the                 
          telephone communications among himself, petitioner, and Ms.                 
          Dellosso were unpleasant.  He also testified that Ms. Dellosso              
          refused to accept full payment for 1993, 1994, and 1995 and                 
          refused to extend the time for a hearing so that their accountant           
          could be present.                                                           
          Evidence of Respondent’s View                                               
               Ms. Dellosso was not called by either party to testify at              
          the hearing in this case.  The parties, however, stipulated as an           
          exhibit a copy of her case activity records (case records).  As             
          one might guess, Ms. Dellosso’s view of their interaction was               
          different from petitioner’s.  According to the case records, on             
          the first occasion Ms. Dellosso spoke with petitioner by                    
          telephone, petitioner was “irate and obnoxious” and “extremely              




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