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issue; (2) submits that there are impermissible “whipsaws” with
related entities or persons; (3) submits that the settlement
officer did not make a determination from petitioners’ tax
returns; (4) claims the settlement officer did not allow them to
raise collection alternatives, including an offer-in-compromise;
(5) claims the settlement officer did not allow sufficient time
for them to retrieve IRS documentation “from their IMF
transcripts-specific”; (6) alleges that the notice does not
comply with administrative rules, regulations, and statutes
because it contains no facts, does not contain a certificate of
compliance by the settlement officer, and is not signed or
attested to by the settlement officer; (7) in docket No. 3489-
05L, alleges that the period of limitations expired for the 1996
and 1997 tax years; and (8) in docket Nos. 3405-05L and 3490-05L,
claims “innocent spouse protection” for Mrs. Gillespie. Mr.
Jones executed each petition on behalf of the named petitioner.
Respondent answered the petitions, denying or otherwise
countering those claims.
The petitions are substantially similar to petitions filed
by Mr. Jones on behalf of taxpayers in at least eight other
cases, six of them calendared for trial at the Las Vegas trial
session. Five of those cases are the subject of our report in
Davis v. Commissioner, released today as T.C. Memo. 2007-201.
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Last modified: November 10, 2007