Estate of Charles A. Lippitz, Deceased, Michael Lippitz, Administrator and Rhita S. Lippitz - Page 4




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          on July 22, 2003.  For all but taxable year 1985, these cases               
          were calendared for trial on February 12, 1990.  The cases were             
          then continued.  Petitioners’ case for taxable year 1985 was                
          first set for trial on December 5, 1994.                                    
               Mr. Lippitz and respondent reached an “Agreement For                   
          Resolving Remaining Issues” in April 2003.  According to                    
          respondent, the only items that remained after this agreement was           
          signed were computations, and then completion of a final                    
          stipulation of settled issues and decision documents.  The                  
          stipulation of settled issues and decision documents were not,              
          however, filed with the Court until November 1, 2006.                       
               It was sometime in 2003 when petitioner alleges she first              
          became aware that respondent had asserted deficiencies in tax               
          against her and Mr. Lippitz for tax years 1980 through 1985, and            
          that petitions on her behalf had been filed relating to the 1980            
          through 1985 tax years.  According to petitioner, prior to 2003,            
          the petitions filed on her behalf had been handled entirely by              
          Mr. Lippitz, and at various points as many as 10 different                  
          lawyers who had entered appearances for petitioner.                         
               After Mr. Lippitz passed away in July 2004, petitioner hired           
          Karen Hawkins to represent her in September 2004.  Ms. Hawkins              
          entered her appearance as counsel for petitioner in November                
          2004.  On January 14, 2005, petitioner filed a motion to amend              
          the petitions to assert a claim for relief under section 6015(c)            







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