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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
claims.
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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Last modified: November 10, 2007