Laura K. Davis, et al. - Page 13

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          that the settlement officer was biased against him on account of            
          his use of the trust system and that there were impermissible               
          whipsaws with related entities or individuals.  Ms. Davis, in               
          docket Nos. 144-05L and 149-05L, claimed that she is an innocent            
          spouse.  Petitioners in each case except for docket No. 145-05L             
          also continued to argue that the assessments of tax on which the            
          collection actions were based were time barred.  Mr. Davis, in              
          docket No. 146-05L, contested the section 6673 penalty.  Mr.                
          Jones and Ms. Lacorte signed each of the objections.                        
          Orders Disposing of Motions for Summary Judgment and Motion for             
               On February 17, 2006, we issued orders granting in full                
          respondent’s motion for summary judgment in docket No. 145-05L              
          and granting in part his motions for summary judgment in the                
          other four cases.  In substantial part, the orders were similar.            
          In each, we concluded that petitioner was prohibited from                   
          challenging the underlying liability.  We found that petitioner             
          had approximately 5-1/2 months to submit information to the                 
          settlement officer regarding collection alternatives but failed             
          to do so.  We determined that, where petitioner had claimed that            
          he needed additional documents, he had not described to the                 
          settlement officer or to the Court those documents or their                 
          relevance.  We concluded that the settlement officer need not               
          have waited any longer than he did to make his determination.  We           
          rejected petitioner’s claim that the settlement officer was                 

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