The Respondent shall also pay the filing fee for a Counter Claim as provided in the Fee Schedule at the time of filing the Counter Claim with the Arbitration Commission.

被申请人在反请求立案时，应按仲裁委员会当时收费表规定的收费标准缴纳仲裁反请求费用。

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The CPA who represented the taxpayers in the examination should have filed a protective claim of refund for tax paid on the lease receipts, but by the time I got involved in the matter the statute of limitations on filing such a claim for refund had long since expired.

FORBES: Representation Before the IRS