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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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