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return, and information about three specified real properties.
In addition, the settlement officer stated that she had
determined the fair market value of petitioner’s residence to be
$699,710 and offered petitioner an opportunity to submit an
appraisal if he disputed this value. The settlement officer
requested all information by October 15, 2004, and informed
petitioner that she would be making her determination at that
time.
Petitioner provided none of the additional documentation
requested by the settlement officer. In an October 4, 2004,
letter to the settlement officer, petitioner stated
that his personal residence was in a “tired” condition and that
his property assessment had been reduced from $600,000 to
“$400,000. plus”. He stated that two of the real properties for
which the settlement officer had requested information were owned
by trusts, and that the other real property was owned by his
wife. He stated that he and his family had experienced health
problems.
By letter dated October 6, 2004, the settlement officer
confirmed a telephone conversation with petitioner in which it
was agreed that petitioner would submit by October 15, 2004, all
of the information requested in her letter dated September 30,
2004. The settlement officer also requested this additional
information: (1) Documents verifying a reduced assessment on
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