Laura K. Davis, et al. - Page 3

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               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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