Laura K. Davis, et al. - Page 9

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          Except as noted, each (1) sought to challenge the tax liability             
          underlying the collection actions at issue; (2) submitted that              
          there were impermissible “whipsaws” with related entities or                
          persons; (3) submitted that the settlement officer did not make a           
          determination from petitioner’s tax returns; (4) claimed the                
          settlement officer did not allow him to raise collection                    
          alternatives, including an offer-in-compromise; (5) claimed the             
          settlement officer did not allow sufficient time for him to                 
          retrieve IRS documentation to test whether the period of                    
          limitations on assessment had expired; (6) alleged that the                 
          assessments were time barred and violated the statute of                    
          limitations; and (7) in docket Nos. 144-05L and 149-05L, claimed            
          “innocent spouse protection” for Ms. Davis.  Mr. Jones executed             
          each petition on behalf of the named petitioner.  Respondent                
          answered the petitions, denying or otherwise countering those               
               The petitions are substantially similar to petitions filed             
          by Mr. Jones on behalf of taxpayers in at least eight other                 
          cases, six of them calendared for trial at the Las Vegas trial              
          session.  Three of those cases are the subject of our report in             
          Gillespie v. Commissioner, released today as T.C. Memo. 2007-202.           

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