Laura K. Davis, et al. - Page 11

                                       - 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 or                      

Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next 

Last modified: November 10, 2007