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Ms. Lacorte’s Appearance
On November 15, 2005, Ms. Lacorte filed an entry of
appearance in each case.
Amended Petitions
On December 16, 2005, approximately 2-1/2 months before
commencement of the Las Vegas trial session, petitioners all
moved for leave to amend petition. Those motions are signed by
Mr. Jones and Ms. Lacorte. The accompanying amended petitions
were lodged with the Court on the same date, and, on December 19,
2005, we ordered respondent to respond to the motions for leave
to amend. On January 17, 2006, respondent informed the Court
that he had no objection to our granting the motions. On January
19, 2006, we granted all of the motions, and we filed the amended
petitions. Mr. Jones executed each amended petition on behalf of
the named petitioners.
In each amended petition, petitioners aver numerous
instances of abuse of discretion by the settlement officer; viz,
(1) She did not give petitioners adequate time to make their
case, including raising collection alternatives, such as an
offer-in-compromise; (2) she failed to provide petitioners a copy
of their individual master file and other relevant documentation;
(3) the period of limitations had expired for the 1996 and 1997
tax years; (4) the settlement officer was biased against
petitioners because of their use of the trust system; (5) there
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Last modified: November 10, 2007