- 29 - average, the cases he brings have merit, some do not: The Orders to Show cannot be properly answered in the context of analysis of individual issues raised on appeal from CDP [sec. 6330] hearings. This is true because there are some “L” [sec. 6330] case docket numbers which standing alone do not have appealable issue[s]. However, in conjunction with other related “L” case docket numbers, and sometimes statutory notice of deficiency docket numbers[, they] have sufficient appealable issues, and “hazards of litigation” which justify settlement of all docket numbers before the Court[,] as agreed upon by petitioners, their counsel, and the IRS Office of Chief Counsel acting on behalf of respondent. All the amended petitions raise substantially the same issues. If Mr. Jones believed that those issues were “appealable issues”, by which term we assume that he means meritorious issues, then there would be no reason for him to make his probabilistic argument; i.e., while some of my cases have no merit, some do, so that, on average, all of my cases have merit, and each is entitled to a portion of some wholesale settlement. That Mr. Jones does indeed take a wholesale approach to representing clients before this Court is supported by his request that we take notice that, during the three trial sessions of the Tax Court in Las Vegas, Nevada, between December 2004 and February 2006, Mr. Jones and his clients settled 67 cases, agreeing to make payments of $2,564,788 with respect to $11,067,835 of claimed liabilities.3 3 That Mr. Jones takes a wholesale approach in representing clients before the Court is also evidenced by the fact that he (continued...)Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 NextLast modified: November 10, 2007