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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 trial
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