- 3 - us (notwithstanding that, in docket No. 3489-05L, there is only one petitioner). Generally, we shall use the term “counsel” to refer to Mr. Jones and Ms. Lacorte. Background Introduction All of these cases began with a petition for review of a determination by respondent’s Appeals Office (Appeals) that respondent might proceed with certain activities to collect unpaid tax (or taxes) owed by petitioners. The docket numbers, petitioners, and years in issue are as follows: Docket No. Petitioner Year(s) 3405-05L Robert & Ines M. Gillespie 1996, 1997, 1998 3489-05L Robert E. Gillespie Asset 1996, 1997, Management Trust, 1998, 1999 Robert E. Gillespie, Trustee 3490-05L Robert E. & Ines M. Gillespie 1999 At the time the petitions were filed, all of the petitioners resided in Wabash, Indiana. The parties to each case have entered into a stipulation of settled issues agreeing, among other things, that Appeals’ determination that respondent might proceed with the collection activities in question in that case should be sustained. The only issues remaining for our decision are the penalties and costs mentioned above. Following the call of these cases from the calendar for the trial session of the Court at Las Vegas, Nevada, commencing on February 27, 2006 (the Las Vegas trialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007