RESPONSES TO DEFENDANT’S FIRST SET OF INTERROGATORIE



Patriot Lawyer

Attorneys for Plaintiff


IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF WYOMING

MARILYN PATRIOT,				)
Plaintiff,		           		)
				    		)
v.				          	) 	Civil No. 2:08-CV-156-CAB
				    		)
UNITED STATES OF AMERICA,			)
Defendant.		         		)
________________________________________________)

RESPONSES TO DEFENDANT’S FIRST SET OF INTERROGATORIES

Plaintiff, by undersigned counsel, provides the following responses to Defendant’s First Set of Requests for Production of Documents.

Plaintiff respectfully reserves the right to supplement any or all of the discovery responses contained herein should additional, potentially responsive information or materials become available. In reserving this right, however, Plaintiff does not admit that any response herein is incomplete or will require supplementation.

REQUEST NO. 1: Any and all documents identified in the responses to the Interrogatories served simultaneously with these Requests.

Response:

Regarding the levies, Plaintiff had sent many letters to the IRS over a period of many years, but cannot find copies of all of them. Some documents are produced herein and include:

Some correspondence with the Michigan pension office:

1. Letter to client dated May 22, 2001
2. Letter from client dated May 29, 2001
3. Letter to client dated August 16, 2001
4. Letter to client dated May 29, 2002
5. Letter to client dated September 16, 2003 in response to client’s letter of July 28, 2003.
6. Letter from client dated November 22, 2005
7. Letter from client dated December 28, 2005
8. Letter to client dated December 13, 2005
9. Letter to client dated January 12, 2006

Some correspondence to the IRS:

1. Letter dated March 10, 1998
2. Letter dated May 12, 1998
3. Letter dated June 29, 1998
4. Letter dated June 6, 2001
5. Letter dated August 3, 2001
6. Letter dated October 25, 2001
7. Letter dated July 5, 2004
8. Letter from the IRS dated Aug. 31, 2004
9. Letter from the IRS dated Oct. 20, 2004
10. Letter dated January 25, 2005
11. Letter dated October 5, 2005
12. Letter dated October 13, 2005
13. Letter dated January 12, 2006
14. Letter dated February 14, 2006
15. Letter dated February 14, 2006
16. Letter dated June 10, 2006
17. Letter dated October 13, 2006
18. Letter dated October 9, 2007 (re: year 2004)
19. Letter dated October 9, 2007 (re: year 2005)

Certainly there are other letters which the IRS should have copies of since it is responsible for keeping records of correspondence.

REQUEST NO. 2: A true and correct copy of the administrative claim that Plaintiff files with the Internal Revenue Service pursuant to 26 CFR 301.7433-1(e), including all attachments, substantiating documentation or evidence that was submitted with the claim.

Response:

The administrative claims found in Plaintiff’s record and sent to the IRS pursuant to 26 CFR 301.7433-1 were dated as follows:
July 15, 2006
August 28, 2006
March 12, 2007
April 22, 2008
April 28, 2008

Patriot Attorney Date: October 23, 2008

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing documents have been served upon the following via pre-paid postal mail on October 23, 2008:

Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, DC 20044

Patriot Attorney