- 4 -
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)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007