From: Erika Kellerhals Sent: Thursday, December 29, 2016 3:37 PM To: Jeffrey E. Subject: Re: We had a conference=call this am (Darren, Chris and I) about next steps and we are in agreement=that we should request a formal administrative hearing in writing — w=thin 30 days of receipt. DPNR will have to appoint a hearing administrator.=We were served the notice of default on the 15th — so we have some ti=e to file a request within the 30 day deadline. There is no point in reques=ing an informal conference. Let me know your=thoughts. =/div> Erika A. K=Ilerhals<=o:p> Membe= Kellerh=ls Ferguson Kroblin PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, VI 00802 Circular 230: To ensure compliance with=the requirements imposed by the IRS, we inform you that any tax advice cont=ined in our communication (including any attachments) was not intended or w=itten to be used, and cannot be used, for the purpose of (i) avoiding any t=x penalty or (ii) promoting, marketing or recommending to another party any=transaction or matter addressed herein. From: "Jeffrey E." <[email protected]> Date: Thursday, December 29, 2016 at 1:26 PM To: Erika Kellerhals spoke to dawn henry, she thought tha= all czm decisions by the commisioner were either appealble to blua o= admin hearing but didnt really know. EFTA_R1_01913802 EFTA02664057

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