- 6 -
supra at 53, but signing court documents and participating in
settlement negotiations are indicators of meaningful
participation; id.; Monsour v. Commissioner, supra.
In Trent v. Commissioner, T.C. Memo. 2002-285, we suggested
that a taxpayer who participated in meetings with an Appeals
officer and who voluntarily signed a decision document generally
would be regarded as having participated meaningfully, regardless
of whether the taxpayer was represented by counsel.1
The legislative history of section 6015 does not provide any
significant guidance as to the definition of “meaningful
participation.”
Petitioner argues that she did not meaningfully participate
in Huynh v. Commissioner, T.C. Summary Opinion 2001-131. She
claims that during the litigation in Huynh she had only minimal
knowledge of the underlying basis for the tax deficiencies, that
she signed various administrative and Court documents merely
under Hong’s direction, and that her testimony therein consisted
solely of “nervous” responses to the Court’s “leading questions”.
Respondent counters that petitioner could have raised the
instant issue of relief from joint liability in Huynh and that
petitioner’s ability to read and understand the documents she
signed, her participation in the pretrial meetings, and her
1 It may be noted that the effective date of sec. 6015 is
not a mitigating factor in the present case, as it was in Trent
v. Commissioner, T.C. Memo. 2002-285.
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