- 11 - determination indicated that “[e]conomic considerations, abuse indications, and compliance factors” were considered and were deemed sufficient to support the proposed settlement. The notice determination explained that Tomi could proceed to trial either if she disagreed with the decision or if Stanley objected. The notice determination also mentioned that the case was scheduled for trial during the week of January 12, 2004. Appeals Officer Baty sent the notice determination to Stanley’s counsel as well. Stanley’s counsel was also provided with a copy of the notice determination and other items in the administrative record at a conference on December 10, 2003, with respondent’s counsel in preparation of trial. Trial on the Section 6015 Claim Stanley’s counsel stated at trial that Stanley did not object to Tomi’s amending the petition to seek relief from joint liability but that Stanley seeks to object now to respondent’s determination that Tomi qualifies for partial relief. At the trial, Appeals Officer Baty authenticated the administrative file and the entire administrative file was admitted into evidence. Appeals Officer Baty testified and explained the factors he considered in deciding to grant Tomi equitable relief under section 6015(f). Stanley neither testified nor refuted any of Appeals Officer Baty’s statements. Stanley only questioned thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011