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clients before this Court, and he was not present in the
courthouse on the date of the Phoenix calendar call.
Prior to the Phoenix calendar call, petitioner discussed her
case with Ms. Huss, and they completed a previously negotiated
agreement to settle. The parties entered into a stipulated
decision document, signed on February 14, 2000, by petitioner and
J. Robert Cuatto, a supervising attorney with respondent’s
Phoenix office.
In relevant part, the stipulated decision document signed by
the parties states:
Pursuant to agreement of the parties in this case,
it is
ORDERED AND DECIDED: That there is a deficiency
in income tax due from the petitioner for the taxable
year 1996 in the amount of $7,121.00; and
That there is no addition to tax due from the
petitioner for the taxable year 1996, under the
provisions of I.R.C. � 6651(a)(1).
* * * * * * *
It is hereby stipulated that the Court may enter
the foregoing decision in this case.
The decision was entered by the Court on February 29, 2000, and
it became final 90 days later on May 29, 2000.
On December 30, 2003, nearly 3-1/2 years after the decision
in her case became final, petitioner wrote a letter to the Court
and asked that the decision be set aside. In the letter
petitioner alleged that she was coerced and intimidated by Ms.
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