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(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 or
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