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After the notice of deficiency was issued, respondent
assigned the case to an IRS Appeals officer. Petitioner’s
counsel had several telephone discussions with respondent’s
Appeals officer but never met with him in person. Petitioner’s
counsel asked the Appeals officer to concede that petitioner was
entitled to relief from joint liability pursuant to former
section 6013(e) but presented no information, documentation, or
other evidence to explain why petitioner qualified for this
relief. Petitioner’s counsel also requested all the information
in respondent’s administrative files regarding the criminal net
worth computations. The Appeals officer denied this request on
the ground that the information sought was grand jury information
that was not available to the Appeals officer. Petitioner’s
counsel then insisted that the case be sent to respondent’s
district counsel.
In her petition to this Court, petitioner disputed
respondent’s determination of the 1990 deficiency and sought
relief from joint liability under former section 6013(e). Theron
filed a separate petition for taxable years 1989 and 1990. The
cases were consolidated for trial, briefing, and opinion.
On May 21, 1998, a trial was held in the consolidated cases.
On July 22, 1998–-before opening briefs were due--section 6015
was enacted, replacing former section 6013(e), which was repealed
generally as of the same date. See Internal Revenue Service
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