Dori R. Merriam, Transferee - Page 11

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                    He asked if we were going to have the house                       
               appraised again and I told him that we would be talking                
               to you and let him know.                                               
                    Jim is up in Roseville today, returning this                      
                    Looking forward to seeing you on Saturday!!                       
          On that day, James Merriam took the paperwork from petitioner and           
          told her that he would take care of it.                                     
               The Tiburon residence was sold on August 6, 1999.                      
          Respondent received $1,815,539 from the sale, which fully paid              
          petitioner’s transferee liability.                                          
          F.   Later Events                                                           
               James Merriam began serving a sentence in Federal prison in            
          January 2002 for securities crimes not related to this case.                
          Petitioner filed for divorce from James Merriam in 2002.                    
               Petitioner retained her current counsel in this case in                
          August 2002.  Petitioner filed her motion for special leave to              
          file motion to vacate decision on July 31, 2003.                            
          A.   Petitioner’s Contentions                                               
               Petitioner moves to vacate the decision in this case on the            
          grounds that it resulted from fraud on the Court by James Merriam           
          and Ted Merriam.  Petitioner contends that James Merriam and Ted            
          Merriam conspired to hold her liable for Napa’s income tax                  
          liability.  She also contends that the stipulation of facts                 
          submitted by Ted Merriam is almost entirely false and is based on           
          documents bearing her forged signature, and that she did not                

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Last modified: May 25, 2011