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apologized to petitioner “for the long delay in getting back” to
him. The letter went on to note that Mr. Barry had “reviewed the
[2000] offer file carefully” and concluded that “all of it is too
dated to be of any use in evaluating” the 2000 offer. Mr. Barry
noted that he needed “current information and documentation to
accurately evaluate” the 2000 offer. In addition to numerous
specific requests for additional information and documentation,
Mr. Barry requested that petitioner provide “copies of all 2002
W-2s received by anyone in * * * [petitioner’s] household”.
Although petitioner was married during all times relevant to this
proceeding, his outstanding tax liabilities did not arise from
joint returns.
Petitioner’s presentation at trial makes it clear that at
the time he received Mr. Barry’s letter, he was less than pleased
with the situation. Nevertheless, in a letter dated July 25,
2003, he responded to Mr. Barry’s request for current financial
information. For the most part he complied; however, in response
to the request for information regarding his spouse, petitioner
noted that his filing status for the years to which his
outstanding tax liabilities and the 2000 offer relate was
“married filing separately”. Petitioner, in effect, objected to
Mr. Barry’s request for information relating to petitioner’s
wife.
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