- 11 - (1) He did not give petitioner adequate time to make his case, including raising collection alternatives, such as an offer-in- compromise; (2) petitioner’s counsel was not provided documentation showing that the IRS had met the requirements of all applicable laws and administrative procedures; (3) the settlement officer failed to provide petitioner a copy of his individual master file; (4) the assessment of tax was backdated and collection was time barred; (5) the settlement officer was biased against petitioner “because of Petitioner’s use of the trust system”; (6) “there are impermissible ‘whipsaws’ with related entities or individuals”; and (7) in docket Nos. 144-05L and 149-05L, Ms. Davis is entitled to “‘innocent spouse protection’”. In each case, respondent denied those averments. The amended petitions are substantially similar to petitions filed by Mr. Jones on behalf of taxpayers in at least six other cases calendared for trial at the Las Vegas trial session. Three of those cases are the subject of our report in Gillespie v. Commissioner, supra. Motions for Summary Judgment and Motion for Penalty On January 5, 2006, in docket Nos. 146-05L and 149-05L, and on January 12, 2006, in the remaining cases, respondent moved for summary judgment. He relied on similar grounds in support of each motion: Since petitioner had received a notice of deficiency with respect to the underlying liability orPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007