- 3 - Background Introduction Each of these cases began with a petition for review of a determination by respondent’s Appeals Office (Appeals) that respondent might proceed with certain activities to collect unpaid tax (or taxes) owed by petitioner. The docket numbers, petitioners, and years in issue are as follows: Docket No. Petitioner Year(s) 144-05L Laura K. Davis 1999 145-05L JLD Asset Management Co., 1999 a/k/a JLD Asset Management Trust, Jeffrey Davis, Trustee 146-05L Jeffrey W. Davis 1997, 1998 147-05L Jeffrey W. Davis 1999 149-05L Laura K. Davis 1997, 1998 Each petitioner resided in Beavercreek, Ohio, at the time he or she (without distinction, he) filed the petition. At the call of these cases from the calendar for the trial session of the Court at Las Vegas, Nevada, commencing on February 27, 2006 (the Las Vegas trial session), the Court received from the parties to each case a proposed decision document sustaining Appeals’ determination that respondent might proceed with the collection activities in question in that case. We filed each proposed decision document as a stipulation of settlement to facilitate the Court’s dealing with the penalty and costs issues before us today. We ordered each petitioner to show cause in writing why, in each case in which he is involved, a penaltyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007