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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
Penalty
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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