U.S. Department of Justice
Tax Division
Civil Trial Section, Eastern Region
_______________________________________________________________________________________________________________________________________
April 6, 2012
VIA FEDERAL EXPRESS
Kathy J. Patriot
123 Main Street
Anytown, US 04939
Re: Patriot v. Department of the Treasury, et al., No. 2:11-cv-xxxx (E.D. Pa.)
Dear Ms. Patriot,
I have been assigned to represent the United States in this lawsuit. From your complaint, I understand that an attorney with the Office of Chief Counsel, Internal Revenue Service, wrote a letter to PNC Bank requesting records concerning income paid to you. The Internal Revenue Service has decided to withdraw this informal request. The Chief Counsel attorney who wrote the letter has been instructed to witdraw it.
I ask that you please dismiss this federal lawsuit. For your convenience, I have prepared a draft stipulation of dismissal under Federal Rule of Civil Procedure 41(a)(1)(A). This will be sufficient to dismiss the lawsuit. Please sign the stipulation and return it to me by mail or delivery service. I will then file it with the court.
Thank you for your cooperation. Should you have any questions, please phone me at 202-307-0854.
Sincerely yours,
s/ W. Bradley Russell
Trial Attorney
Civil Trial Section, Eastern Region
Enclosure
Copies:
Cindy Park, Esquire
Internal Revenue Service
Mellon Independence Center
701 Market Street, Suite 2200
Philadelphia, Pennsylvania 19106
Facsimile: 215-861-1070
Elizabeth M. Bux
Internal Revenue Service
Office of Chief Counsel
Kinston Building, Mail Stop 24
2303 West Meadowview Road
Greensboro, North Carolina 27407
Facsimile: 336-378-2114
*****************************************************************************************************************
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KATHY J. PATRIOT ) CIVIL ACTION ) v. ) DEPARTMENT OF THE TREASURY ) NO. 11-4XXX PNC BANK )
STIPULATION FOR DISMISSAL
It is hereby stipulated between Kathy J. Patriot and the United States of America (named in the complaint as Department of the Treasury) that this case be dismissed with prejudice, the parties to bear their respective costs, including any possible attorney’s fees or other expenses of litigation.
Dated: ___________________, 2012.
_____________________
Kathy J. Patriot
Pro se
123 Main St.
Anytown, US 12345
Zane D. Memeger
United States Attorney
John A. DiCicco
Principal Deputy Assistant Attorney General
Tax Division
___________________________
W. Bradley Russell
Trial Attorney, Tax Division
U.S. Department of Justice
Post Office Box 227
Ben Franklin Station
Washington, DC 20044
Telephone: (202) 307-0854
E-Mail: william.b.russell@usdoj.gov