CA, Inc.'s Answer and Counterclaim - Reed Smith
CA, Inc.'s Answer and Counterclaim - Reed Smith
CA, Inc.'s Answer and Counterclaim - Reed Smith
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From the state tax library of <strong>Reed</strong> <strong>Smith</strong> LLPwww.reedsmith.com/DEtaxfor other related documents, please email ksollie@reedsmith.comnext several months in good faith in an attempt to come to a resolution of this matter. <strong>CA</strong> alsoadmits in response to the allegations set forth in Paragraph 53 of the Verified AmendedComplaint that, on or about June 3, 2008, the State sent a letter to <strong>CA</strong>, said document speakingfor itself. <strong>CA</strong> also states that the document referred to by the State in Paragraph 53 of theVerified Amended Complaint is the best evidence of its own content <strong>and</strong>, therefore, <strong>CA</strong> deniesthe State<strong>'s</strong> attempt to summarize or characterize the document<strong>'s</strong> purpose or contents <strong>and</strong> statesthat no further response to the allegations in this paragraph regarding the documents is required.In addition, <strong>CA</strong> admits in response to the allegations contained in Paragraph 53 of the VerifiedAmended Complaint only that the State assessed interest against <strong>CA</strong> on June 3, 2008, but deniesthe validity of said assessment <strong>and</strong> the State<strong>'s</strong> right to assess interest against <strong>CA</strong>. Furtheranswering, <strong>CA</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 53 of theVerified Amended Complaint.54. Admits in response to the allegations set forth in Paragraph 54 of the VerifiedAmended Complaint only that <strong>CA</strong> sent a letter to the State on or about June 26, 2008 in thecontext of settlement <strong>and</strong>/or compromise, said document speaking for itself. Further answering,<strong>CA</strong> states that the document referred to by the State in Paragraph 54 of the Verified AmendedComplaint is the best evidence of its own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt tosummarize or characterize the document<strong>'s</strong> purpose or contents <strong>and</strong> states that no further responseto the allegations in this paragraph regarding the document is required. Further answering, <strong>CA</strong>states that the State did not accept <strong>CA</strong><strong>'s</strong> offered payment made in settlement <strong>and</strong>/or compromise<strong>and</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 54 of the Verified AmendedComplaint.55. Admits in response to the allegations set forth in Paragraph 55 of the VerifiedAmended Complaint only that the State selected <strong>CA</strong> for audit in July 2008, sent <strong>CA</strong> a letter dated- 16 –
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