- 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 NextLast modified: November 10, 2007