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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 penalty
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