Stuart Hult - Page 4




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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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